Any tax advice contained on this website is not intended or written by the practitioner to be used, and cannot be used by any taxpayer, for the purpose of (i) avoiding penalties that may be
imposed on the taxpayer, and (ii) supporting the promotion or marketing of any transactions or matters addressed herein.
Use of a disclaimer does not change the high degree of care and attention that we devote to our tax advice. Moreover, the inclusion of the disclaimer does not indicate that penalties could be
imposed on the transaction at issue, but rather merely indicates that the advice we have provided you in such communication does not preclude the IRS from asserting penalties. Finally, the use of
such a disclaimer to avoid unnecessary legal expenses is similar to the approach adopted by most tax practitioners.