IRS Circular 230: In compliance with the requirements imposed by the IRS pursuant to Circular 230, we inform you that

(i) any written tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code;

(ii) this communication was written to support the promotion or marketing of the transactions or matters addressed herein; and

(iii) a taxpayer should seek advice based on the taxpayer‘s particular circumstances from an independent tax advisor.