Notes to the Financial Statements — Continued government.
See, Fifth Third Bancorp & Subsidiaries v.  United States, 1:05-CV-350 (S. D.  Ohio April 18, 2008).
In December 2008, this case was conditionally dismissed without prejudice to the parties until June 2, 2009, for the purpose of pursuing a settlement.
In the event a settlement is not reached, the case will be reinstated to the Court calendar.
The IRS has completed the pre-filing Compliance Assurance Process for the 2007 tax year and the company and the IRS did not reach agreement on the treatment of the LILO transactions within the 2007 tax return, a net tax deduction of $41 million.
In connection with its audit of Con Edison’s federal income tax return for the tax year 2006, the IRS disallowed $43 million of net tax deductions taken with respect to both of the LILO transactions for the tax year.
Con Edison filed an appeal of this audit level disallowance with the Appeals Office of the IRS, where consideration of this matter is pending.
In connection with its audit of Con Edison’s federal income tax returns for the tax years 1998 through 2005, the IRS indicated that it intends to disallow $332 million of net tax deductions taken with respect to both of the LILO transactions for the tax years.
If and when these audit level disallowances become appealable, Con Edison intends to file appeals of the disallowances with the Appeals Office of the IRS.
Con Edison believes that its LILO transactions have been correctly reported, and has not recorded any reserve with respect to the disallowance of tax losses, or related interest, in connection with its LILO transactions.
Con Edison’s estimated tax savings, reflected in its financial statements, from the two Note L – Income Tax The components of income tax are as follows LILO transactions through December 31, 2008, in the aggregate, was $188 million.
If Con Edison were required to repay all or a portion of these amounts, it would also be required to pay interest of up to $78 million at December 31, 2008.
In July 2006, the FASB issued FSP No.
FAS 13-2, “Accounting for a Change or Projected Change in the Timing of Cash Flows Relating to Income Taxes Generated by a Leveraged Lease Transaction,” which became effective for fiscal years beginning after December 15, 2006.
This FSP requires the expected timing of income tax cash flows generated by Con Edison’s LILO transactions to be reviewed at least annually.
If the expected timing of the cash flows is revised, the rate of return and the allocation of income would be recalculated from the inception of the LILO transactions, and the company would be required to recalculate the accounting effect of the LILO transactions, which would result in a charge to earnings that could have a material adverse effect on the company’s results of operations.
Note K – Goodwill In 2008 and 2007, Con Edison completed impairment tests for its goodwill of $406 million related to the O&R merger, and determined that it was not impaired.
For the impairment test, $245 million and $161 million of the goodwill were allocated to Con Edison of New York and O&R, respectively.
In 2008, Con Edison completed impairment tests for the goodwill of $5 million related to two energy services companies acquired by Con Edison Solutions, and determined that it was not impaired.
## Table 0 ##
THE GOLDMAN SACHS GROUP, INC.  AND SUBSIDIARIES Notes to Consolidated Financial Statements As of December 2016, the U. S.  federal and state and local net operating loss carryforwards were $207 million and $800 million, respectively.
If not utilized, the U. S.  federal net operating loss carryforward and the state and local net operating loss carryforward will begin to expire in 2017.
If these carryforwards expire, they will not have a material impact on the firm’s results of operations.
As of December 2016, foreign net operating loss carryforwards were $1.39 billion, substantially all of which do not expire.
The firm had no foreign tax credit carryforwards and no related net deferred income tax assets as of December 2016 and December 2015.
The firm had no capital loss carryforwards and no related net deferred income tax assets as of December 2016 and December 2015.
The valuation allowance increased by $42 million during 2016 and increased by $9 million during 2015.
The increases in 2016 and 2015 were primarily due to an increase in deferred tax assets from which the firm does not expect to realize any benefit.
The firm permanently reinvests eligible earnings of certain foreign subsidiaries and, accordingly, does not accrue any U. S.  income taxes that would arise if such earnings were repatriated.
As of December 2016 and December 2015, this policy resulted in an unrecognized net deferred tax liability of $6.18 billion and $5.66 billion, respectively, attributable to reinvested earnings of $31.24 billion and $28.55 billion, respectively.
Unrecognized Tax Benefits The firm recognizes tax positions in the consolidated financial statements only when it is more likely than not that the position will be sustained on examination by the relevant taxing authority based on the technical merits of the position.
A position that meets this standard is measured at the largest amount of benefit that will more likely than not be realized on settlement.
A liability is established for differences between positions taken in a tax return and amounts recognized in the consolidated financial statements.
The accrued liability for interest expense related to income tax matters and income tax penalties was $141 million and $101 million as of December 2016 and December 2015, respectively.
The firm recognized interest expense and income tax penalties of $27 million, $17 million and $45 million for 2016, 2015 and 2014, respectively.
It is reasonably possible that unrecognized tax benefits could change significantly during the twelve months subsequent to December 2016 due to potential audit settlements.
However, at this time it is not possible to estimate any potential change.
The table below presents the changes in the liability for unrecognized tax benefits.
This liability is included in “Other liabilities and accrued expenses.
” See Note 17 for further information.
## Table 1 ##
Regulatory Tax Examinations The firm is subject to examination by the U. S.  Internal Revenue Service (IRS) and other taxing authorities in jurisdictions where the firm has significant business operations, such as the United Kingdom, Japan, Hong Kong and various states, such as New York.
The tax years under examination vary by jurisdiction.
The firm does not expect completion of these audits to have a material impact on the firm’s financial condition but it may be material to operating results for a particular period, depending, in part, on the operating results for that period.
The table below presents the earliest tax years that remain subject to examination by major jurisdiction.
## Table 2 ##
During the second quarter of 2016, the Joint Committee on Taxation finalized its review of the U. S.  Federal examinations of fiscal 2008 through calendar 2010.
The completion of the review did not have a material impact on the firm’s effective income tax rate.
The examinations of 2011 and 2012 began in 2013.
The firm has been accepted into the Compliance Assurance Process program by the IRS for each of the tax years from 2013 through 2017.
This program allows the firm to work with the IRS to identify and resolve potential U. S.  federal tax issues before the filing of tax returns.
The 2013 through 2015 tax years remain subject to post-filing review.
Research and Development

<table><tr><td></td><td colspan="3">Con Edison</td><td colspan="3">Con Edison of New York</td></tr><tr><td> (Millions of Dollars)</td><td>2008</td><td>2007</td><td>2006</td><td>2008</td><td>2007</td><td>2006</td></tr><tr><td>Charge/(benefit) to operations:</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>State</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Current</td><td>$52</td><td>$30</td><td>$4</td><td>$8</td><td>$20</td><td>$—</td></tr><tr><td>Deferred – net</td><td>82</td><td>72</td><td>86</td><td>84</td><td>70</td><td>78</td></tr><tr><td>Federal</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Current</td><td>-3</td><td>72</td><td>73</td><td>-106</td><td>46</td><td>55</td></tr><tr><td>Deferred – net</td><td>387</td><td>284</td><td>250</td><td>416</td><td>262</td><td>228</td></tr><tr><td>Amortization of investment tax credits</td><td>-6</td><td>-6</td><td>-6</td><td>-6</td><td>-6</td><td>-6</td></tr><tr><td> Total Charge to Operations</td><td>512</td><td>452</td><td>407</td><td>396</td><td>392</td><td>355</td></tr><tr><td>Charge/(benefit) to other income:</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>State</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Current</td><td>1</td><td>8</td><td>-8</td><td>-1</td><td>—</td><td>-6</td></tr><tr><td>Deferred – net</td><td>2</td><td>-8</td><td>1</td><td>2</td><td>—</td><td>5</td></tr><tr><td>Federal</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Current</td><td>4</td><td>-9</td><td>-13</td><td>-4</td><td>5</td><td>-12</td></tr><tr><td>Deferred – net</td><td>5</td><td>-6</td><td>2</td><td>4</td><td>-5</td><td>7</td></tr><tr><td> Total Charge/(Benefit) to Other Income</td><td>12</td><td>-15</td><td>-18</td><td>1</td><td>—</td><td>-6</td></tr><tr><td> TOTAL</td><td>$524</td><td>$437</td><td>$389</td><td>$397</td><td>$392</td><td>$349</td></tr></table>
<table><tr><td></td><td colspan="3">Year Ended or as of December</td></tr><tr><td><i>$ in millions</i></td><td>2016</td><td>2015</td><td>2014</td></tr><tr><td>Beginning balance</td><td>$ 825</td><td>$ 871</td><td>$ 1,765</td></tr><tr><td>Increases based on tax positions related to the current year</td><td>113</td><td>65</td><td>204</td></tr><tr><td>Increases based on tax positions related to prior years</td><td>188</td><td>158</td><td>263</td></tr><tr><td>Decreases based on tax positions related to prior years</td><td>-88</td><td>-205</td><td>-241</td></tr><tr><td>Decreases related to settlements</td><td>-186</td><td>-87</td><td>-1,112</td></tr><tr><td>Exchange rate fluctuations</td><td>—</td><td>23</td><td>-8</td></tr><tr><td> Ending balance</td><td>$ 852</td><td>$ 825</td><td>$ 871</td></tr><tr><td>Related deferred income tax asset</td><td>231</td><td>197</td><td>172</td></tr><tr><td> Net unrecognized tax benefit</td><td>$ 621</td><td>$ 628</td><td>$ 699</td></tr></table>
<table><tr><td> Jurisdiction</td><td> As of December 2016</td></tr><tr><td>U.S. Federal</td><td> 2011</td></tr><tr><td>New York State and City</td><td> 2007</td></tr><tr><td>United Kingdom</td><td> 2014</td></tr><tr><td>Japan</td><td> 2014</td></tr><tr><td>Hong Kong</td><td> 2007</td></tr></table>

Question: In the year with lowest amount of Current, what's the increasing rate of Deferred – net for Con Edison ?