that it is intended, that the Merger cialify as a tax-free reorganization underiliaso 36ca)(1)(A) of the Internal Revenue Code; . • • :•• • ag,sor,,y0b; that the forth and provisions of/die:Merger Agteeospdtihe and they Wezeby are adopted airdapprth:e4.• • • • • • .RES014VED; m connection With the