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IRS CIRCULAR 230 – DISCLOSURE NOTICE: IRS Circular 230 regulates written communications about federal tax matters between tax advisers and their clients. To the extent this web site and/or any attachment is a written tax advice communication, it is not a full “covered opinion.” Accordingly, this advice is not intended and cannot be used for the purpose of avoiding penalties that may be imposed by the IRS regarding the transaction or matters discussed herein.