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Circular 230 Disclosure: Pursuant to IRS Circular 230 and the regulations thereunder, the owner and contributors to this website inform you that, unless otherwise expressly indicated, any tax advice contained on this website is not intended or written to be used, and cannot be used, for the purpose of avoiding tax-related penalties imposed under the Internal Revenue Code or other applicable tax law, or for promoting, marketing or recommending to another party any transaction, arrangement or other matter addressed herein. Please contact the website’s author to discuss whether a formal written opinion can be provided.
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