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Please be advised that, based on current IRS rules and standards, any tax advice contained in this communication (including any attachments) is not intended to be written or used, for the purpose of (i) avoiding penalties under the Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. This advice is intended solely for the person to whom it is addressed; no one else should rely on the tax advice provided herein.