Disclaimer

This web site is purely a public resource of general information which is intended, but not promised or guaranteed, to be correct, complete, and up-to-date. However, this web site is not intended to be a source of legal advice; hence, the reader should not consider this information to be an invitation for an attorney-client relationship, should not rely on information provided herein, and should always seek the advice of competent counsel in the reader's state. Moreover, any reader who sends an e-mail to the owner of the web site must realize that this unilateral action , and any reply thereto, do not, in and of themselves, create an attorney-client relationship and the reader must have no expectation whatsoever of confidentiality with regard to any information contained in his or her e-mail(s).

Furthermore, the owner of this web site does not wish to represent anyone desiring representation based upon viewing this web site in a state where this web site fails to comply with all laws and ethical rules of that state. In addition, the use of Internet e-mail for confidential or sensitive information is discouraged. Finally, the owner of this web site grants permission to anyone wishing to link to this web site without representation; the owner will gladly remove any link from this web site upon request from the linked entity. This web site is not sponsored or associated with any particular linked entity unless so stated in truth by that entity. The existence of any particular link is simply intended to imply potential interest to the reader.

Circular 230 Statement

Even if the information contained in this web site were construed to be written tax advice, we do not believe any issue discussed in this web site relates to a Listed Transaction. We believe that the strategies and the tax benefits sought referred to herein are consistent with the Internal Revenue Code of 1986 as amended ( Code) and Congressional purpose. Furthermore, we intend this writen advice not to constitute a Reliance Opinion nor a Marketed Opinion nor be issued under Conditions of Confidentiality within the meaning of section 10.35 ( b) (4) , ( b) (5) and (b) (6) respectively of IRS Circular 230. Specifically, you are hereby advised that any written U.S. federal tax advice contained herein was not intended nor written to be used, and cannot be used, by any person for the purpose of avoiding tax penalties that may be imposed under the Internal Revenue Code with respect to any transaction or matter addressed. Without our prior express written consent, no person may use any written tax advice contained in this web site in the promotion, marketing or recommendation of a partnership or other entity, investment plan or arrangement to one or more taxpayers. Nevertheless, there is no limitation on disclosure of the tax treatment or tax structure of any transaction that is the subject of the written advice herein contained.