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NOTICE: This forum is a means of discussion among colleagues and no information posted herein is intended to nor shall it constitute the rendition of legal or tax advice. To ensure compliance with IRS requirements, however, and although nothing provided on this forum is intended to constitute U.S. federal tax advice, any U.S. federal tax advice that is contained in this communication is not intended or written to be used, and cannot be used, to (i) avoid penalties under the Internal Revenue Code or (ii) promote, market or recommend to another party any transaction or tax-related matter. IRS Circular 230 Disclosure: U.S. federal tax advice in the foregoing message from the Participants in the InterActive Legal Discussion Forum is not intended or written to be, and cannot be used, by any person for the purpose of avoiding tax penalties that may be imposed regarding the transactions or matters addressed. Some of that advice may have been written to support the promotion or marketing of the transactions or matters addressed within the meaning of IRS Circular 230, in which case you should seek advice based on your particular circumstances from an independent tax advisor.