Sales which May Give Rise to Suit under Section 16(b) of the Securities Exchange Act of 1934

In General For Federal tax purposes, when the sale of property at a profit within six months after the purchase of the property could subject a person to suit under Section 16(b) of the Securities Exchange Act of 1934, the person's rights in the property are treated as subject to a substantial risk of forfeiture and as not transferable until the earlier of (i) the expiration of such six-month period, or (ii) the first day on which the sale of such property at a profit will not subject the person to suit under Section 16(b) of the Securities Exchange Act of 1934.

Effective Date For personal income tax purposes, this paragraph applies to property transferred after December 31, 2004.