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CIRCULAR 230 NOTICE:
Under recently issued IRS regulations, we must inform you that any U.S. tax advice contained at this web site was not intended or written to be used, and cannot be used, by the reader for the purpose of avoiding penalties that may be imposed under federal tax law.
By regulation, a taxpayer cannot rely on professional advice to avoid federal tax penalties unless that advice is reflected in a comprehensive tax opinion that conforms to strict requirements.