IRS Circular 230 Statement

Even if the information contained in this web site were construed to be written tax advice, we do not believe any issue discussed in this web site relates to a Listed Transaction.

We believe that the strategies and the tax benefits sought referred to herein are consistent with the Internal Revenue Code of 1986 as amended (Code) and Congressional purpose. Furthermore, we intend this written advice not to constitute a Reliance Opinion nor a Marketed Opinion nor be issued under Conditions of Confidentiality within the meaning of section 10.35 (b) (4), (b) (5) and (b) (6) respectively of IRS Circular 230.

Specifically, you are hereby advised that any written U.S. federal tax advice contained herein was not intended nor written to be used, and cannot be used, by any person for the purpose of avoiding tax penalties that may be imposed under the Internal Revenue Code with respect to any transaction or matter addressed.

Without our prior express written consent, no person may use any written tax advice contained in this web site in the promotion, marketing or recommendation of a partnership or other entity, investment plan or arrangement to one or more taxpayers. Nevertheless, there is no limitation on disclosure of the tax treatment or tax structure of any transaction that is the subject of the written advice herein contained.