Opinions expressed in The Tax Adviser are those of the individual writers and may differ from policies of the American Institute of Certified Public Accountants, the Tax Division, or its other divisions and committees. This publication is designed to provide accurate and authoritative information on the subjects covered. It is sold, however, with the understanding that the publisher, editors, and authors are not engaged in rendering legal, accounting, or other professional service. If specific tax advice or other expert assistance is required, the services of a competent professional person should be sought. The information in this publication is not intended or written to be used as, and cannot be used as or considered to be written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing, or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute, or other purposes. The contents of The Tax Adviser are indexed in ProQuest Accounting & Tax, a product of ProQuest, available online at proquest.com