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IRS CIRCULAR 230 NOTICE: The following disclosure is now required pursuant to IRS Circular 230 which regulates the provision of written tax advice by federal tax practitioners. Any tax advice reflected in this email or any attachment hereto was not intended or written by the practitioner to be used, and it cannot be used by the taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer. This disclosure will also confirm that there is no limitation imposed hereby on the disclosure of the tax treatment or tax structure of any transaction that is the subject of this email or of any attachment hereto.
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