The Fund has not obtained, nor does it plan to obtain, a private letter ruling from the IRS regarding the validity of the "Federal Income Tax Considerations" section of this Memorandum as it may apply to the Fund's activities. Such rulings, even if obtained, are not binding on the IRS. Accordingly, such discussion should not be construed as tax advice. You should consult with your own tax adviser to determine the effect an investment in the Fund will have on your own individual tax situation. In the event the IRS takes the position that the Fund is to be treated as an "investment company" and/or an "investment partnership" for tax purposes, this may result in an adverse taxable event to you based upon your contribution. Such an event would significantly reduce the overall profitability of your investment in the Fund. You should review the section entitled "Federal Income Tax Considerations" section of this Memorandum for a more complete discussion of certain aspects of the tax risks inherent in the acquisition of interests in the Fund.