NOTICE: Pursuant to Treasury Circular 230 regulations, we wish to advise you that this written tax advice (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 or promoting to another party any transaction or matter addressed herein. Our conclusions are based on tax law, regulations, case law and the facts as presented to us. Any changes to tax law or inaccuracies in the facts received could affect the validity of our conclusions. We will not update this advice for subsequent changes to tax law, regulations, case law or other information provided to us.