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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.
Any metadata contained or embedded in this email and in any attached document(s) is not intended for the recipient, but is confidential and contains the thought processes, mental impressions and work product of the sending attorney or on whose behalf the information is transmitted. Pursuant to Model Rule 4.4(b) and Tennessee Formal Ethics Opinion 2004-F-150, the recipient is obligated to: (1) refrain from reviewing the metadata, (2) notify the sender, and (3) abide by the sending attorney’s instructions regarding disposition thereof.
