is a formal tax opinion) was not intended or written to be used, and cannot be used, f=r the purpose of (i) avoiding tax-related penalties under the Internal Rev=nue Code, or (ii) promoting, marketing, or recommending to another party a=y tax-related matter addressed herein. 2 EFTA_R1_01678523 EFTA02533966 CONFID

is a formal tax opinion) was not intended or written to be used, and cannot be used, f=r the purpose of (i) avoiding tax-related penalties under the Internal Rev=nue Code, or (ii) promoting, marketing, or recommending to another party a=y tax-related matter addressed herein. CONFIDENTIAL! This electronic message and