Please be aware of the following issues when using the library:

• Each memorandum contains a date on which the memorandum was produced. That the memoranda have not been updated for legislative, regulatory, or judicial changes occurring after the production date. Such changes could materially affect the conclusions stated in the memoranda.

• The conclusions stated in the memoranda are often highly fact- dependent and that any variation from the facts set forth in the memoranda could materially affect the conclusions stated therein.

• The memoranda, unless otherwise stated, deal with federal income tax issues only. There could be significant state or local income tax implications as well as federal, state, or local non-income tax implications of the facts set forth in the memoranda. These issues are not addressed.

• There can be no assurance that the conclusions set forth in the memoranda will not be challenged by the Internal Revenue Service; and, if so challenged, there can be no assurance that the positions articulated in the memoranda can be sustained though the appeals process or in the courts.

• The U.S. Congress may enact tax laws, the Internal Revenue Service may issue rulings and other pronouncements, the U.S. Treasury Department may issue tax regulations, and the Federal judiciary may render interpretive decisions which are retroactive in effect. Accordingly, there can be no assurance that the conclusions set forth the memoranda will not be negated by retroactive changes in the tax law and/or its interpretation.

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