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Circular 230 Notice: The contents of this web site are not intended or written to be used, and cannot be used, by anyone for the purpose of (i) avoiding U.S. Tax penalties, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. This web site is not treated as a marketed opinion because “(a) the advice was not intended or written to be used, and it cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer; (b) the advice was not written to support the promotion or marketing of the transaction(s) or matter(s) addressed by any written advice; and (c) the taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor.” [31 C.F.R. Sections 10.35(B)(4)(ii); 10.35(B)(5)(i); and (b)(5)(ii)(a), (b) and (c).]