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Any tax advice herein is based on the facts provided to us and on current tax law including judicial and administrative interpretation and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer.  Tax law is subject to continual change, at times on a retroactive basis and may result in incremental taxes, interest or penalties.  Should the facts provided to us be incorrect or incomplete or should the law or its interpretation change, our advice may be inappropriate.  We are not responsible for updating our advice for changes in law or interpretation after the date hereof.

U.S. Tax (IRS Circular 230):  Nothing in this communication (including in any attachment) is U.S. tax or other legal advice that is intended or written to be used and it cannot be used, by any person for the purpose of (i) avoiding penalties under U.S. federal, state or local tax laws, or (ii) promoting, marketing or recommending to any person any transaction or matter addressed therein. 

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All partners at McGovern Hurley LLP hold their partnership interests through professional corporations.