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This website and any statements and descriptions regarding the law or other matters are not legal advice and may not be relied upon by the viewer.  The laws, regulations and rules referred to and relied upon in this website are subject to change.  Attorney Fitzgerald’s statements are intended for informational purposes.  Viewers are advised to consult with an attorney before taking action.  Nothing contained in this message was intended or written to be used, or can be used by any taxpayer or may be relied upon or used by any taxpayer for the purpose of avoiding penalties imposed under the Internal Revenue Code of 1986, as amended.  Any written statement contained in this message relating to any Federal tax transaction or matter may not be used by any person to support the promotion or marketing of or to recommend any Federal tax transaction(s) or matter(s) addressed in this website.  Any taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor with respect to any Federal tax transaction or matter contained in this website.