Attached is a redline showing the changes made to this proposed article pursuant to comments received from Thomas Goeglein. This article is now being submitted to Action Line for publication. Arthur J. Menor Partner ________________________________ Shutts & Bowen LLP 1100 CityPlace Tower, 525 Okeechobee Boulevard | West Palm Beach, FL 33401 Direct: (561) 650-8510 | Fax: (561) 822-5510 E-Mail <mailto:AMenor@shutts.com> | Biography <http://www.shutts.com/index.cfm/fa/attorney.bio/atty/8051073b-833e-444a -8b57-a6912a6d5435/Arthur_J_Menor.cfm/> | V-Card <http://www.shutts.com/index.cfm/fa/attorney.vcf/atty/8051073b-833e-444a -8b57-a6912a6d5435/Arthur_J_Menor.cfm/> | Website <http://www.shutts.com/> IRS CIRCULAR 230 NOTICE: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. Thank you.