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Circular 230 Disclosure: Please note that Treasury regulations effective June 20, 2005 impose extensive requirements for a formal tax opinion. Since this communication (including any attachments) is not such a formal tax opinion, we are required to advise you that it was not intended or written to be used, and it cannot be used (i) for the purpose of avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like further information, please contact us.