Disclaimer: Any federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any transaction or matter addressed herein. For additional information about this disclosure, please see https://www.irs.gov/tax-professionals/office-of-professional-responsibility-and-circular-230.