To insure compliance with Treasury Regulations (31 C.F.R. Part 10, §10.35), we are required to inform you that any tax advice contained in any communication must be considered as preliminary only and cannot be used by you or anyone else for the purpose of avoiding penalties imposed by the Internal Revenue Code or other law or for the purpose of marketing or recommending to any other party any transaction, arrangement, or other matter. Only a formal opinion letter that reviews ALL facts and discloses ALL potential issues can be treated as “formal” tax advice on which one may rely for purposes of avoiding certain tax penalties. Should you desire a formal opinion on a particular tax matter for the purpose of avoiding the imposition of any penalties, our firm must be engaged for that purpose; and we shall discuss further the Treasury requirements that must be met and whether it is possible to meet those requirements under the circumstances, as well as the anticipated time and fees involved.