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    U. S. Treasury Circular 230 Notice: Any tax advice contained in this website was not intended or written to be used, and cannot be used, for the purpose of: (a) avoiding penalties that may be imposed under the IRS Code or by any other applicable tax authority; or (b) promoting, marketing or recommending to another party any tax-related matter addressed herein. We provide this disclosure to assure compliance with new standards of professional practice, pursuant to which certain tax advice must satisfy requirements as to form and substance.