subsidiaries, provided certain criteria are met.
Management elected to apply the Act for 2005 and recorded a one-time tax benefit of $70 million for the year ended December 31, 2005.
At December 31, 2006 and 2005, federal income taxes had not been provided on $4.4 billion and $1.4 billion of undistributed earnings of foreign subsidiaries, earned prior to 1987 and after 1997 that have been reinvested for an indefinite period of time.
If the earnings were distributed, an additional $573 million and $249 million of tax expense, net of credits for foreign taxes paid on such earnings and for the related foreign withholding taxes, would have resulted in 2006 and 2005.
Note 19 – Fair Value of Financial Instruments SFAS No.107, “Disclosures About Fair Value of Financial Instruments” (SFAS 107), requires the disclosure of the estimated fair value of financial instruments.
The fair value of a financial instrument is the amount at which the instrument could be exchanged in a current transaction between willing parties, other than in a forced or liquidation sale.
Quoted market prices, if available, are utilized as estimates of the fair values of financial instruments.
Since no quoted market prices exist for certain of the Corporation’s financial instruments, the fair values of such instruments have been derived based on management’s assumptions, the estimated amount and timing of future cash flows and estimated discount rates.
The estimation methods for individual classifications of financial instruments are described more fully below.
Different assumptions could significantly affect these estimates.
Accordingly, the net realizable values could be materially different from the estimates presented below.
In addition, the estimates are only indicative of the value of individual financial instruments and should not be considered an indication of the fair value of the combined Corporation.
The provisions of SFAS 107 do not require the disclosure of the fair value of lease financing arrangements and nonfinancial instruments, including Goodwill and Intangible Assets such as purchased credit card, affinity, and trust relationships.
Short-term Financial Instruments The carrying value of short-term financial instruments, including cash and cash equivalents, time deposits placed, federal funds sold and purchased, resale and repurchase agreements, commercial paper and other shortterm investments and borrowings, approximates the fair value of these instruments.
These financial instruments generally expose the Corporation to limited credit risk and have no stated maturities or have short-term maturities and carry interest rates that approximate market.
Financial Instruments Traded in the Secondary Market and Strategic Investments Held-to-maturity securities, AFS debt and marketable equity securities, trading account instruments, long-term debt traded actively in the secondary market and strategic investments have been valued using quoted market prices.
The fair values of trading account instruments, securities and strategic investments are reported in Notes 3 and 5 of the Consolidated Financial Statements.
Derivative Financial Instruments All derivatives are recognized on the Consolidated Balance Sheet at fair value, net of cash collateral held and taking into consideration the effects of legally enforceable master netting agreements that allow the Corporation to settle positive and negative positions with the same counterparty on a net basis.
For exchange-traded contracts, fair value is based on quoted market prices.
For non-exchange traded contracts, fair value is based on dealer quotes, pricing models or quoted prices for instruments with similar characteristics.
The fair value of the Corporation’s derivative assets and liabilities is presented in Note 4 of the Consolidated Financial Statements.
Loans Fair values were estimated for groups of similar loans based upon type of loan and maturity.
The fair value of loans was determined by discounting estimated cash flows using interest rates approximating the Corporation’s current origination rates for similar loans and adjusted to reflect the inherent credit risk.
Where quoted market prices were available, primarily for certain residential mortgage loans and commercial loans, such market prices were utilized as estimates for fair values.
Substantially all of the foreign loans reprice within relatively short timeframes.
Accordingly, for foreign loans, the net carrying values were assumed to approximate their fair values.
Deposits The fair value for deposits with stated maturities was calculated by discounting contractual cash flows using current market rates for instruments with similar maturities.
The carrying value of foreign time deposits approximates fair value.
For deposits with no stated maturities, the carrying amount was considered to approximate fair value and does not take into account the significant value of the cost advantage and stability of the Corporation’s long-term relationships with depositors.
The book and fair values of certain financial instruments at December 31, 2006 and 2005 were as follows:
## Table 0 ##
Note 20 – Business Segment Information The Corporation reports the results of its operations through three business segments: Global Consumer and Small Business Banking, Global Corporate and Investment Banking, and Global Wealth and Investment Management.
The Corporation may periodically reclassify business segment results based on modifications to its management reporting methodologies and changes in organizational alignment.
Global Consumer and Small Business Banking provides a diversified range of products and services to individuals and small businesses through its primary businesses: Deposits, Card Services, Mortgage and Home Equity.
Global Corporate and Investment Banking serves domestic and international issuer and investor clients, providing financial services, specialized industry expertise and local delivery through its primary businesses: Business Lending, Capital Markets and Advisory Services, and Treasury Services.
These businesses provide traditional bank deposit and loan products to large corporations and institutional clients, capital-raising solutions, advisory services, derivatives capabilities, equity and debt sales and trading for clients, as well as treasury management and payment services.
Global Wealth and Investment Management offers investment services, estate management, financial planning services, fiduciary management, credit and banking expertise, and diversified asset management products to institutional clients, as well as affluent and highnet-worth individuals through its primary businesses: The Private Bank, Columbia Management and Premier Banking and Investments.
In support of these activities, the business may take positions in these products and participate in market-making activities dealing in government securities, equity and equity-linked securities, high-grade and high-yield corporate debt securities, commercial paper, and mortgage-backed and asset-backed securities.
Underwriting debt and equity, securities research and certain market-based activities are executed through Banc of America Securities, LLC which is a primary dealer in the U. S.  and several other countries.
Capital Markets and Advisory Services market-based revenue includes Net Interest Income, Noninterest Income, including equity income, and Gains (Losses) on Sales of Debt Securities.
We evaluate our trading results and strategies based on market-based revenue.
The following table presents further detail regarding market-based revenue.
Sales and trading revenue is segregated into fixed income from liquid products (primarily interest rate and commodity derivatives, foreign exchange contracts and public finance), credit products (primarily investment and noninvestment grade corporate debt obligations and credit derivatives), and structured products (primarily commercial mortgage-backed securities, residential mortgage-backed securities, and collateralized debt obligations), and equity income from equity-linked derivatives and cash equity activity
## Table 1 ##
Net Income increased $345 million, or 26 percent, market-based revenue increased $1.4 billion, or 21 percent, driven primarily by increased sales and trading fixed income activity of $738 million, or 21 percent, due to a favorable market environment as well as benefits from previous investments in personnel and trading infrastructure.
Marketbased revenue also benefited from an increase in Investment Banking Income of $585 million, or 31 percent, primarily driven by increased market activity and continued strength in debt underwriting.
Noninterest Expense increased $770 million, or 16 percent, due to higher Personnel expense, including performance-based incentive compensation, and Other General Operating costs.
Treasury Services Treasury Services provides integrated working capital management and treasury solutions to clients worldwide through our network of proprietary offices and special clearing arrangements.
Our clients include multinationals, middle-market companies, correspondent banks, commercial real estate firms and governments.
Our products and services include treasury management, trade finance, foreign exchange, short-term credit facilities and short-term investing options.
Net Interest Income is derived from interest and noninterest-bearing deposits, sweep investments, and other liability management products.
Deposit products provide a relatively stable source of funding and liquidity.
We earn net interest spread revenues from investing this liquidity in earning assets through client facing lending activity and our ALM activities.
The revenue is attributed to the deposit products using our funds transfer pricing process which takes into account the interest rates and maturity characteristics of the deposits.
Noninterest Income is generated from payment and receipt products, merchant services, wholesale card products, and trade services and is comprised primarily of service charges which are net of market-based earnings credit rates applied against noninterest-bearing deposits.
Net Income increased $337 million, or 18 percent, primarily due to an increase in Net Interest Income, higher Service Charges and all other income, partially offset by increased Noninterest Expense.
Net Interest Income from Treasury Services increased $505 million, or 15 percent, driven primarily by wider spreads associated with higher short-term interest rates as we effectively managed pricing in a rising interest rate environment.
This was partially offset by the impact of a four percent decrease in Treasury Services average deposit balances driven primarily by the slowdown in the mortgage and title business reducing real estate escrow and demand deposit balances.
Service Charges and wholesale card products increased seven percent and 14 percent benefiting from increased client penetration and both market and product expansion.
Noninterest Expense increased $99 million, or three percent, due to higher Personnel expense and Other General Operating costs.
ALM/Other ALM/Other is comprised primarily of our Latin American operations in Brazil, Chile, Argentina and Uruguay, and our commercial operations in Mexico, as well as our Asia Commercial Banking business.
These operations primarily service indigenous and multinational corporations, small businesses and affluent consumers.
Brazilian operations were included through September 1, 2006, and the Asia Commercial Banking business was included through December 29, 2006, the effective dates of the sales of these operations.
ALM/Other also includes an allocation of a portion of the Corporation’s Net Interest Income from ALM activities.
For more information on our Latin American and Asian operations, see Foreign Portfolio beginning on page 71.
Net Income increased $91 million, or 15 percent, which included the $720 million gain (pre-tax) recorded on the sale of our Brazilian operations.
The Corporation sold its operations in exchange for approximately $1.9 billion in equity of Banco Itaú, Brazil’s second largest nongovernment-owned banking company.
The $1.9 billion equity investment in Banco Itaú is recorded in Other Assets in Strategic Investments.
For more information on our Strategic Investments, see All Other beginning on page 55.
The Corporation also completed the sale of its Asia Commercial Banking business to CCB for cash resulting in a $165 million gain (pre-tax) that was recorded in all other income.
Partially offsetting these increases was a decrease in Net Interest Income of $461 million driven by the impact of ALM activities and the impact of the sale of our Brazilian operations in the third quarter of 2006.
The Provision for Credit losses was negative $21 million, compared to negative $327 million in 2005.
The change in the Provision for Credit Losses was driven by the benefits from the release of reserves in 2005 related to an improved risk profile in Latin America.
Gains on Sales of Debt Securities decreased $128 million to $18 million in 2006.
Noninterest expense decreased $147 million, or 12 percent, primarily driven by lower expenses after the sale of our Brazilian operations in the third quarter of 2006.
## Table 2 ##
(1) Includes small business commercial – domestic charge offs of $911 million and $409 million in 2007 and 2006.
Small business commercial – domestic charge offs were not material in 2005, 2004 and 2003.
(2) Includes small business commercial – domestic recoveries of $42 million and $48 million in 2007 and 2006.
Small business commercial – domestic recoveries were not material in 2005, 2004 and 2003.
(3) Ratios do not include loans measured at fair value in accordance with SFAS 159 at and for the year ended December 31, 2007.
Loans measured at fair value were $4.59 billion at December 31, 2007.
(4) In 2007, the impact of SOP 03-3 decreased net charge-offs by $75 million.
Excluding the impact of SOP 03-3, net charge-offs as a percentage of average loans and leases outstanding measured at historical cost in 2007 would have been 0.85 percent and the ratio of the allowance for loan and lease losses to net charge-offs would have been 1.77 percent at December 31, 2007.
(5) In 2006, the impact of SOP 03-3 decreased net charge-offs by $288 million.
Excluding the impact of SOP 03-3, net charge-offs as a percentage of average loans and leases outstanding measured at historical cost in 2006 would have been 0.74 percent, and the ratio of the allowance for loan and lease losses to net charge-offs would have been 1.87 percent at December 31, 2006.
The Company consolidates the assets and liabilities of several entities from which it leases office buildings and corporate aircraft.
These entities have been determined to be variable interest entities and the Company has been determined to be the primary beneficiary of these entities.
Due to the consolidation of these entities, the Company reflects in its balance sheet: property, plant and equipment of $156 million and $183 million, other assets of $14 million and $12 million, long-term debt of $150 million (including current maturities of $6 million) and $192 million (including current maturities of $8 million), minority interest liabilities of $22 million and $6 million, and other accrued liabilities of $1 million and $0, as of May 27, 2007 and May 28, 2006, respectively.
The liabilities recognized as a result of consolidating these entities do not represent additional claims on the general assets of the Company.
The creditors of these entities have claims only on the assets of the specific variable interest entities.
OBLIGATIONS AND COMMITMENTS As part of its ongoing operations, the Company enters into arrangements that obligate the Company to make future payments under contracts such as debt agreements, lease agreements, and unconditional purchase obligations (i. e. , obligations to transfer funds in the future for fixed or minimum quantities of goods or services at fixed or minimum prices, such as “take-or-pay” contracts).
The unconditional purchase obligation arrangements are entered into by the Company in its normal course of business in order to ensure adequate levels of sourced product are available to the Company.
Capital lease and debt obligations, which totaled $3.6 billion at May 27, 2007, are currently recognized as liabilities in the Company’s consolidated balance sheet.
Operating lease obligations and unconditional purchase obligations, which totaled $645 million at May 27, 2007, are not recognized as liabilities in the Company’s consolidated balance sheet, in accordance with generally accepted accounting principles.
A summary of the Company’s contractual obligations at the end of fiscal 2007 is as follows (including obligations of discontinued operations):

<table><tr><td></td><td colspan="4"> December 31</td></tr><tr><td></td><td colspan="2"> 2006</td><td colspan="2">2005</td></tr><tr><td>(Dollars in millions)</td><td> Book Value</td><td> Fair Value</td><td>Book Value</td><td>Fair Value</td></tr><tr><td> Financial assets</td><td></td><td></td><td></td><td></td></tr><tr><td>Loans<sup>-1</sup></td><td>$675,544</td><td>$679,738</td><td>$545,238</td><td>$542,626</td></tr><tr><td> Financial liabilities</td><td></td><td></td><td></td><td></td></tr><tr><td>Deposits</td><td>693,497</td><td>693,041</td><td>634,670</td><td>633,928</td></tr><tr><td>Long-term debt</td><td>146,000</td><td>148,120</td><td>100,848</td><td>101,446</td></tr></table>
<table><tr><td>(Dollars in millions)</td><td> 2006</td><td>2005</td></tr><tr><td> Investment banking income</td><td></td><td></td></tr><tr><td>Advisory fees</td><td>$338</td><td>$295</td></tr><tr><td>Debt underwriting</td><td>1,822</td><td>1,323</td></tr><tr><td>Equity underwriting</td><td>316</td><td>273</td></tr><tr><td> Total investment banking income</td><td>2,476</td><td>1,891</td></tr><tr><td> Sales and trading</td><td></td><td></td></tr><tr><td>Fixed income:</td><td></td><td></td></tr><tr><td>Liquid products</td><td>2,021</td><td>1,890</td></tr><tr><td>Credit products</td><td>825</td><td>634</td></tr><tr><td>Structured products</td><td>1,449</td><td>1,033</td></tr><tr><td> Total fixed income</td><td>4,295</td><td>3,557</td></tr><tr><td>Equity income</td><td>1,451</td><td>1,370</td></tr><tr><td> Total sales and trading<sup>-1</sup></td><td>5,746</td><td>4,927</td></tr><tr><td> Total Capital Markets and Advisory Services market-based revenue<sup>-1</sup></td><td>$8,222</td><td>$6,818</td></tr></table>
<table><tr><td>(Dollars in millions)</td><td>2007</td><td>2006</td><td>2005</td><td>2004</td><td>2003</td></tr><tr><td> Allowance for loan and lease losses, January 1</td><td>$9,016</td><td>$8,045</td><td>$8,626</td><td>$6,163</td><td>$6,358</td></tr><tr><td> Adjustment due to the adoption of SFAS 159</td><td>-32</td><td>–</td><td>–</td><td>–</td><td>–</td></tr><tr><td> LaSalle balance, October 1, 2007</td><td>725</td><td>–</td><td>–</td><td>–</td><td>–</td></tr><tr><td> U.S. Trust Corporation balance, July 1, 2007</td><td>25</td><td>–</td><td>–</td><td>–</td><td>–</td></tr><tr><td> MBNA balance, January 1, 2006</td><td>–</td><td>577</td><td>–</td><td>–</td><td>–</td></tr><tr><td> FleetBoston balance, April 1, 2004</td><td>–</td><td>–</td><td>–</td><td>2,763</td><td>–</td></tr><tr><td> Loans and leases charged off</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Residential mortgage</td><td>-79</td><td>-74</td><td>-58</td><td>-62</td><td>-64</td></tr><tr><td>Credit card – domestic</td><td>-3,410</td><td>-3,546</td><td>-4,018</td><td>-2,536</td><td>-1,657</td></tr><tr><td>Credit card – foreign</td><td>-452</td><td>-292</td><td>–</td><td>–</td><td>–</td></tr><tr><td>Home equity</td><td>-286</td><td>-67</td><td>-46</td><td>-38</td><td>-38</td></tr><tr><td>Direct/Indirect consumer</td><td>-1,885</td><td>-857</td><td>-380</td><td>-344</td><td>-322</td></tr><tr><td>Other consumer</td><td>-346</td><td>-327</td><td>-376</td><td>-295</td><td>-343</td></tr><tr><td>Total consumer charge-offs</td><td>-6,458</td><td>-5,163</td><td>-4,878</td><td>-3,275</td><td>-2,424</td></tr><tr><td>Commercial – domestic<sup>-1</sup></td><td>-1,135</td><td>-597</td><td>-535</td><td>-504</td><td>-857</td></tr><tr><td>Commercial real estate</td><td>-54</td><td>-7</td><td>-5</td><td>-12</td><td>-46</td></tr><tr><td>Commercial lease financing</td><td>-55</td><td>-28</td><td>-315</td><td>-39</td><td>-132</td></tr><tr><td>Commercial – foreign</td><td>-28</td><td>-86</td><td>-61</td><td>-262</td><td>-408</td></tr><tr><td>Total commercial charge-offs</td><td>-1,272</td><td>-718</td><td>-916</td><td>-817</td><td>-1,443</td></tr><tr><td>Total loans and leases charged off</td><td>-7,730</td><td>-5,881</td><td>-5,794</td><td>-4,092</td><td>-3,867</td></tr><tr><td> Recoveries of loans and leases previously charged off</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Residential mortgage</td><td>22</td><td>35</td><td>31</td><td>26</td><td>24</td></tr><tr><td>Credit card – domestic</td><td>347</td><td>452</td><td>366</td><td>231</td><td>143</td></tr><tr><td>Credit card – foreign</td><td>74</td><td>67</td><td>–</td><td>–</td><td>–</td></tr><tr><td>Home equity</td><td>12</td><td>16</td><td>15</td><td>23</td><td>26</td></tr><tr><td>Direct/Indirect consumer</td><td>512</td><td>247</td><td>132</td><td>136</td><td>141</td></tr><tr><td>Other consumer</td><td>68</td><td>110</td><td>101</td><td>102</td><td>88</td></tr><tr><td>Total consumer recoveries</td><td>1,035</td><td>927</td><td>645</td><td>518</td><td>422</td></tr><tr><td>Commercial – domestic<sup>-2</sup></td><td>128</td><td>261</td><td>365</td><td>327</td><td>224</td></tr><tr><td>Commercial real estate</td><td>7</td><td>4</td><td>5</td><td>15</td><td>5</td></tr><tr><td>Commercial lease financing</td><td>53</td><td>56</td><td>84</td><td>30</td><td>8</td></tr><tr><td>Commercial – foreign</td><td>27</td><td>94</td><td>133</td><td>89</td><td>102</td></tr><tr><td>Total commercial recoveries</td><td>215</td><td>415</td><td>587</td><td>461</td><td>339</td></tr><tr><td>Total recoveries of loans and leases previously charged off</td><td>1,250</td><td>1,342</td><td>1,232</td><td>979</td><td>761</td></tr><tr><td>Net charge-offs</td><td>-6,480</td><td>-4,539</td><td>-4,562</td><td>-3,113</td><td>-3,106</td></tr><tr><td>Provision for loan and lease losses</td><td>8,357</td><td>5,001</td><td>4,021</td><td>2,868</td><td>2,916</td></tr><tr><td>Other</td><td>-23</td><td>-68</td><td>-40</td><td>-55</td><td>-5</td></tr><tr><td>Allowance for loan and lease losses, December 31</td><td>11,588</td><td>9,016</td><td>8,045</td><td>8,626</td><td>6,163</td></tr><tr><td> Reserve for unfunded lending commitments, January 1</td><td>397</td><td>395</td><td>402</td><td>416</td><td>493</td></tr><tr><td>Adjustment due to the adoption of SFAS 159</td><td>-28</td><td>–</td><td>–</td><td>–</td><td>–</td></tr><tr><td>LaSalle balance, October 1, 2007</td><td>124</td><td>–</td><td>–</td><td>–</td><td>–</td></tr><tr><td>FleetBoston balance, April 1, 2004</td><td>–</td><td>–</td><td>–</td><td>85</td><td>–</td></tr><tr><td>Provision for unfunded lending commitments</td><td>28</td><td>9</td><td>-7</td><td>-99</td><td>-77</td></tr><tr><td>Other</td><td>-3</td><td>-7</td><td>–</td><td>–</td><td>–</td></tr><tr><td>Reserve for unfunded lending commitments, December 31</td><td>518</td><td>397</td><td>395</td><td>402</td><td>416</td></tr><tr><td> Allowance for credit losses, December 31</td><td>$12,106</td><td>$9,413</td><td>$8,440</td><td>$9,028</td><td>$6,579</td></tr><tr><td>Loans and leases outstanding measured at historical cost at December 31</td><td>$871,754</td><td>$706,490</td><td>$573,791</td><td>$521,813</td><td>$371,433</td></tr><tr><td>Allowance for loan and lease losses as a percentage of total loans and leases outstanding measured at historical cost at December 31<sup>-3</sup></td><td>1.33%</td><td>1.28%</td><td>1.40%</td><td>1.65%</td><td>1.66%</td></tr><tr><td>Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31</td><td>1.23</td><td>1.19</td><td>1.27</td><td>1.34</td><td>1.25</td></tr><tr><td>Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding measured at historical cost atDecember 31<sup>-3</sup></td><td>1.51</td><td>1.44</td><td>1.62</td><td>2.19</td><td>2.40</td></tr><tr><td>Average loans and leases outstanding measured at historical cost during the year</td><td>$773,142</td><td>$652,417</td><td>$537,218</td><td>$472,617</td><td>$356,220</td></tr><tr><td>Net charge-offs as a percentage of average loans and leases outstanding measured at historical cost during the year<sup>-3, 4, 5</sup></td><td>0.84%</td><td>0.70%</td><td>0.85%</td><td>0.66%</td><td>0.87%</td></tr><tr><td>Allowance for loan and lease losses as a percentage of total nonperforming loans and leases measured at historical cost atDecember 31</td><td>207</td><td>505</td><td>532</td><td>390</td><td>215</td></tr><tr><td>Ratio of the allowance for loan and lease losses at December 31 to net charge-offs<sup>-4, 5</sup></td><td>1.79</td><td>1.99</td><td>1.76</td><td>2.77</td><td>1.98</td></tr></table>

Question: What's the average of the Deposits for Financial liabilities for Book Value in the years where Total investment banking income for Investment banking income is greater than 0? (in million)