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4. IRS Circular 230 Disclosure

Pursuant to U.S. Treasury Department Regulations, Portola Law is now required to advise you that, unless otherwise expressly indicated, any federal tax advice contained in this communication is not intended or written to be used, and may not be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein.