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The drafter of the tax articles in this e-newsletter did not intend nor write the advice to be used to avoid any penalty imposed by a taxing authority, nor may any user/recipient of this document use this document's written tax advice for that purpose. This document's tax advice was written specifically to support the promotion or marketing of the transaction/matter addressed by the written tax advice. Therefore, any user/recipient of this document should seek an independent tax professional's advice regarding the user/recipient's particular circumstances.

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