Any advice provided herein represents our best judgment and should not be used by you for the purpose of avoiding penalties that may be imposed on you under Section 6662(d) of the Internal Revenue Code. Any advice provided herein is as of this date and is limited to the conclusions we have included herein and these conclusions are based on the information you provided to us. Our conclusions may be different if any of the information provided to us is incomplete or inaccurate. In rendering our advice, we rely on the tax law, regulations and case law. These laws and regulations may change and any such changes could affect the validity of our conclusions. We will not update our advice for subsequent changes to the tax law, regulations or case law.