To the extent any of the material on this Web Site contains an opinion on one or more Federal tax issues, such opinion cannot be relied upon and cannot be used for the purpose of avoiding penalties.  If you would like a written opinion on one or more of the Federal tax issues addressed on this Web Site or the material enclosed upon which you can rely for the purpose of avoiding penalties you should contact a licensed lawyer.  Nothing contained on this Web Site & none of the documents you are given through this Web Site  are or should be interpreted as legal or tax advice. You should not take any action upon anything contained on this Web Site or any of the documents you are given on this Web Site unless and until you first discuss the individual fact situation with an attorney licensed in your state who is knowledgeable in Federal tax issues and the tax issues relative to the state in which you reside.