In the course of preparing tax returns, Brennan & Associates applies customary practices intended to fulfill our professional responsibilities regarding the tax treatment of reported positions in a cost effective manner. This document defines our professional responsibilities and the standards that we employed in preparing your tax returns. We find that by more clearly defining our professional service responsibilities, and your responsibilities as a taxpayer, we can prevent any uncertainties in the preparation of your income tax returns. By signing your tax returns, you are agreeing to the conditions and limitations described below.

Scope of Services. Our services in representing your tax returns are limited to tax return representation of you before a tax authority. If you need tax planning services or other representation during an examination, these additional services would constitute a separate engagement at an additional cost.

Responsibility for Accuracy. We exercise professional care to include all pertinent information in your tax returns; however, you are ultimately responsible for your tax returns. By signing your returns, you are verifying that they are true, correct and complete. You should review each tax return carefully before signing it, and bring any questionable items or omissions to our attention.

No Review of Facts. We have not investigated or verified any facts underlying the transactions reported on your tax return. If the actual facts are different from the facts represented to us, or if there are other facts of which we are not aware, the reporting of the transactions could be materially different than that reported on the returns prepared by us.

Level of Assurance. Except as we may have advised you in the course of preparing your returns, we are not aware of any position reported on your tax returns that does not stand a realistic possibility of success if litigated. The “more likely than not” standard means that a reasonable and well-informed analysis by a person knowledgeable in the tax law would lead to a conclusion that the position has approximately a one in two, or greater, likelihood of being sustained on its merits. It is possible that there could be a “more likely than not” possibility of success for more than one tax treatment of an item.

Oral Advice is Preliminary. In connection with our return preparation services, we may discuss with you our views regarding the tax treatment of certain items. Please note that oral advice should be considered our preliminary reaction and should not be relied upon in the absence of written confirmation.

Changes in Law. In evaluating whether a position has a “more likely than not” possibility of success, we have applied the Internal Revenue Code of 1986, as amended (the “Code”), and applicable state tax law as of the date of our preparation of your returns. Subsequent changes in the Code, state tax law, or regulations thereunder, or the issuance of a new case or ruling authority, could materially and adversely affect likelihood of success on the merits of the positions reported on your tax returns. Our preparation of your returns is not an undertaking on our part to advise you of any changes in law.

Reportable Transactions. The Code requires that you disclose on your Federal tax return certain “reportable transactions” or “listed transactions.” There are significant financial penalties for failure to disclose these transactions, and these penalties apply even if the transaction does not lead to an understatement of tax. Certain states require similar disclosures on your state tax returns. Except as disclosed on your tax returns you have not made us aware of any reportable transactions or listed transactions that are required to be reported on your tax returns. We have not undertaken an investigation to evaluate whether there are any transactions that are required to be reported on your returns.

Potential Federal Tax Penalties. The Code imposes penalties for certain tax underpayments. Whether and how a taxpayer can avoid these penalties depends to some extent on whether a transaction is deemed a tax shelter. A “tax shelter” is defined as any plan or arrangement, if a significant purpose of the plan or arrangement, based on objective evidence, is the avoidance or evasion of Federal income tax. We have not evaluated any transaction reported on your returns to determine whether they constitute a “tax shelter” under this definition.

For transactions reported on your Federal income tax returns that are not “tax shelters,” you can avoid the application of the Code 6662 accuracy related penalty if either (i) your position is supported by substantial authority or (ii) you make an adequate disclosure of the transaction on your Federal income tax return.

The “substantial authority” standard is a higher standard than the “more likely than not” standard, and we have not attempted to determine whether any positions reported on your tax return are supported by substantial authority. However, had we noted any position that we felt lacked substantial authority, we would have brought it to your attention prior to the completion of your tax returns.

The standard for avoiding the Code 6662 penalty for items attributable to a tax shelter is significantly higher than the “substantial authority” standard, and it could be much more difficult to avoid this penalty if it were ultimately determined that you participated in a tax shelter.

Possibility of Litigation. If the IRS or another tax authority adopts a position contrary to the positions reported on your tax returns, it might be necessary to pursue administrative appeals or litigation. Decisions of whether and how to pursue administrative appeals or litigation may be based on considerations of cost, publicity, and other matters unrelated to the technical merits of a tax position.

Engagement of Other Parties. You have authorized Brennan & Associates to allow employees of Brennan and Company, CPA, PC access to your files, financial information and other confidential information.