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Any U.S. Federal tax advice contained in our communications is not intended or written to be used, and cannot be used, by any person for the purposes of (1) avoiding U.S. Federal tax penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended, or (2) promoting, marketing or recommending to another party any tax-related matter addressed herein, whether an entity, investment plan or other transaction.
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