Government Regulations contained in Circular 230 regulate written communications about Federal tax matters, including e-mail, between us and our clients. Such communications are either opinions or other written communications. This is not an opinion. It is other written communication. As such, it was not written to be relied upon, by itself, to avoid any tax penalties. In order to receive assurances of protection from tax penalties from a written communication, by itself, you should get a "covered opinion" or "limited scope opinion." If you would like to discuss an opinion letter relating to the matter described below or any other matter, please contact me and I will explain what is involved and what it will cost.