CIRCULAR 230 DISCLOSURE:  To assure compliance with Treasury Department rules governing tax practice, we inform you that any advice (including in any third party posts, commentary or editorial) (1) was not written and is not intended to be used, and cannot be used, for the purpose of avoiding any Federal tax penalty that may be imposed on the taxpayer, (2) may not be used in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein, and (3) does not constitute a formal tax opinion and thus may not be relied upon as such.