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Note: In accordance with IRS Circular 230, the information on this Web site is not intended or written to be used, and cannot be used as or considered a "covered  opinion" or other written tax advice and should not be relied upon for the purpose of avoiding tax-related penalties under the Internal Revenue Code; promoting, marketing, or recommending to another party any transaction or tax-related matter (s) addressed herein; for IRS audit, tax dispute, or other purposes.