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The information contained in this communication does not constitute tax advice that may be used or relied upon by the recipient or any other person to avoid imposition of any penalty imposed by the Internal Revenue Service. Written tax advice that can be relied upon by the recipient to avoid imposition of a penalty by the Internal Revenue Service must be provided in the form of a “formal tax opinion” that complies with Circular 230 issued by the Internal Revenue Service. Please contact a member of our firm if you need a “formal tax opinion” from our firm concerning any federal tax issue.

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