Table of Contents ADOBE SYSTEMS INCORPORATED NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (Continued) repatriated, the related U. S.  tax liability may be reduced by any foreign income taxes paid on these earnings.
As of November 30, 2012, the cumulative amount of earnings upon which U. S.  income taxes have not been provided is approximately $2.9 billion.
The unrecognized deferred tax liability for these earnings is approximately $0.8 billion.
As of November 30, 2012, we have U. S.  net operating loss carryforwards of approximately $33.7 million for federal and $77.7 million for state.
We also have federal, state and foreign tax credit carryforwards of approximately $1.9 million, $18.0 million and $17.6 million, respectively.
The net operating loss carryforward assets, federal tax credits and foreign tax credits will expire in various years from fiscal 2017 through 2032.
The state tax credit carryforwards can be carried forward indefinitely.
The net operating loss carryforward assets and certain credits are subject to an annual limitation under Internal Revenue Code Section 382, but are expected to be fully realized.
In addition, we have been tracking certain deferred tax attributes of $45.0 million which have not been recorded in the financial statements pursuant to accounting standards related to stock-based compensation.
These amounts are no longer included in our gross or net deferred tax assets.
Pursuant to these standards, the benefit of these deferred tax assets will be recorded to equity if and when they reduce taxes payable.
As of November 30, 2012, a valuation allowance of $28.2 million has been established for certain deferred tax assets related to the impairment of investments and certain foreign assets.
For fiscal 2012, the total change in the valuation allowance was $23.0 million, of which $2.1 million was recorded as a tax benefit through the income statement.
Accounting for Uncertainty in Income Taxes During fiscal 2012 and 2011, our aggregate changes in our total gross amount of unrecognized tax benefits are summarized as follows (in thousands):
## Table 0 ##
As of November 30, 2012, the combined amount of accrued interest and penalties related to tax positions taken on our tax returns and included in non-current income taxes payable was approximately $12.5 million.
We file income tax returns in the U. S.  on a federal basis and in many U. S.  state and foreign jurisdictions.
We are subject to the continual examination of our income tax returns by the IRS and other domestic and foreign tax authorities.
Our major tax jurisdictions are the U. S. , Ireland and California.
For California, Ireland and the U. S. , the earliest fiscal years open for examination are 2005, 2006 and 2008, respectively.
We regularly assess the likelihood of outcomes resulting from these examinations to determine the adequacy of our provision for income taxes and have reserved for potential adjustments that may result from the current examinations.
We believe such estimates to be reasonable; however, there can be no assurance that the final determination of any of these examinations will not have an adverse effect on our operating results and financial position.
In August 2011, a Canadian income tax examination covering our fiscal years 2005 through 2008 was completed.
Our accrued tax and interest related to these years was approximately $35 million and was previously reported in long-term income taxes payable.
We reclassified approximately $17 million to short-term income taxes payable and decreased deferred tax assets by approximately $18 million in conjunction with the aforementioned resolution.
The timing of the resolution of income tax examinations is highly uncertain as are the amounts and timing of tax payments that are part of any audit settlement process.
These events could cause large fluctuations in the balance sheet classification of current and non-current assets and liabilities.
The Company believes that before the end of fiscal 2013, it is reasonably possible
will begin to expire in 2032.
A deferred tax asset for these tax attribute carryforwards was recorded, and no valuation allowance has been provided, as it is more likely than not that the deferred tax asset will be realized.
Con Edison recorded a full valuation allowance of $3 million in 2015 against its charitable contribution carryforward from 2011.
Due to the expiration of this charitable contribution carryforward in 2016, Con Edison wrote off the deferred tax asset and corresponding valuation allowance.
Charitable contributions carryforward of $5 million and $6 million for 2015 and 2016, respectively, that will expire in 2020 and 2021, respectively, were recorded as a deferred tax asset and no valuation allowance has been provided, as it is more likely than not that the deferred tax asset will be realized.
In addition, a $12 million valuation allowance for New York City net operating loss carryforward and a $4 million valuation allowance for state net operating losses carryforward has been provided; as it is not more likely than not that the deferred tax asset will be realized.
In 2014, tax legislation was enacted in the State of New York that reduced the corporate franchise tax rate from 7.1 percent to 6.5 percent, beginning January 1, 2016.
The application of this legislation decreased Con Edison’s accumulated deferred tax liabilities by $74 million ($69 million for CECONY), decreased Con Edison’s regulatory asset for future income tax by $11 million ($10 million for CECONY) and increased Con Edison’s regulatory liability by $62 million ($59 million for CECONY).
The impact of this tax legislation on Con Edison’s effective tax rate was not material, and there was no impact on CECONY’s effective tax rate for the year ended December 31, 2014.
Under the Taxpayer Relief Act of 2012, 50 percent bonus depreciation expired on December 31, 2013.
The Tax Increase Prevention Act of 2014 extended bonus depreciation for another year through December 31, 2014.
As a result of the extension of bonus depreciation to 2014, Con Edison filed a refund request with the IRS in January 2015 to recover $224 million ($128 million for CECONY) in estimated federal tax payments and received the refund in March 2015.
The Protecting Americans from Tax Hikes Act of 2015 extended bonus depreciation for property acquired and placed in service during 2015 through 2019.
The bonus depreciation percentage is 50 percent for property placed in service during 2015, 2016 and 2017 and phases down to 40 percent in 2018, and 30 percent in 2019.
As a result of the extension of bonus depreciation to 2015, Con Edison filed a refund request with the IRS in January 2016 to recover $160 million in estimated federal tax payments.
In February 2016, Con Edison received a refund of estimated taxes paid in the amount of $160 million ($143 million for CECONY).
Uncertain Tax Positions Under the accounting rules for income taxes, the Companies are not permitted to recognize the tax benefit attributable to a tax position unless such position is more likely than not to be sustained upon examination by taxing authorities, including resolution of any related appeals and litigation processes, based solely on the technical merits of the position.
A reconciliation of the beginning and ending amounts of unrecognized tax benefits for Con Edison and CECONY follows:
## Table 1 ##
In 2016, Con Edison reached a settlement with New York State on two claims it had filed in previous years and reversed $11 million in uncertain tax positions.
Of this amount, $8 million ($5 million, net of federal taxes) reduced Con Edison’s effective tax rate.
The amount related to CECONY was $2 million ($1 million, net of federal taxes), all of which reduced CECONY’s effective tax rate.
Current year additions of $21 million are for tax credits and prior years' claims filed in 2016.
Fiscal 2011 Acquisitions: TCT International Co. , Ltd.  On June 1, 2011, the Company completed the acquisition of 100% of the equity interest in TCT International Co. , Ltd.  (“TCT”) and subsidiaries, a privately-held distributor of medical products, including the Company’s ThinPrep Pap Test, related instruments and other diagnostic and surgical products.
TCT’s operating subsidiaries are located in Beijing, China.
The Company’s acquisition of TCT has enabled it to obtain an established nationwide sales organization and customer support infrastructure in China, which is consistent with the Company’s international expansion strategy.
TCT has been integrated within the Company’s international operations, and its results are primarily reported within the Company’s Diagnostics reporting segment and to a lesser extent within the Company’s GYN Surgical reporting segment from the date of acquisition.
The Company concluded that the acquisition of TCT did not represent a material business combination, and therefore, no pro forma financial information has been provided herein.
The purchase price of $148.4 million was comprised of $135.0 million in cash, of which $100.0 million was paid up-front and $35.0 million plus a working capital adjustment $13.2 million, was deferred for one year.
In addition, $0.9 million was paid in the first quarter of fiscal 2012 for additional assets acquired.
The deferred payment was recorded on a present value basis of $47.5 million in purchase accounting to reflect fair value, and such payment was being accreted through interest expense over the one year deferral period.
The $35.0 million and a portion of the working capital adjustment of $8.5 million were paid in the fourth quarter of fiscal 2012.
As agreed to by the parties, the remainder is due after the completion of fiscal 2013.
In addition, the majority of the former shareholders of TCT may receive two annual contingent earn-out payments (subject to adjustment) not to exceed $200.0 million less the deferred payment.
The contingent earn-out payments are based on a multiple of incremental revenue growth for the one year periods beginning January 1, 2011 and January 1, 2012 as compared to the respective prior year periods, and are payable after the first and second anniversaries from the date of acquisition, respectively.
Since these payments are contingent on future employment, they are being recognized as compensation expense ratably over the required service periods, the first and second year anniversaries from the date of acquisition.
Based on actual and projected revenues for the TCT business, the Company recorded compensation expense of $75.5 million and $17.6 million in fiscal 2012 and 2011, respectively.
In the third quarter of fiscal 2012, the first measurement period was completed, and the Company paid the earned contingent consideration of $54.0 million in the fourth quarter of fiscal 2012.
As of September 29, 2012, the Company has accrued $39.1 million for the second contingent earn-out payment.
The Company did not issue any equity awards in connection with this acquisition, and third-party transaction costs were not significant.
The allocation of the purchase price was based on estimates of the fair value of assets acquired and liabilities assumed as of June 1, 2011.
The components of the purchase price allocation consisted of the following:
## Table 2 ##
In connection with the purchase price allocation, the Company determined that the separately identifiable intangible assets were customer relationships, business licenses, and trade names related to the TCT company name.
The fair value of the intangible assets was determined through the application of the income approach, and the cash flow projections were discounted at 12.5%.
Customer relationships relate to relationships that TCT’s founders and sales force have developed with obstetricians, gynecologists, hospitals, and clinical laboratories.
Customer relationships, business licenses and trade names are being amortized over a weighted average period of 12.7 years, 10 years and 12 years, respectively.
The excess of the purchase price over the fair value of the tangible net assets and intangible assets acquired was recorded to goodwill.
The goodwill recognized is attributable to the established sales and distribution network of TCT and expected synergies that the Company will realize from this acquisition.
None of the goodwill is expected to be deductible for income tax purposes.

<table><tr><td></td><td>2012</td><td>2011</td></tr><tr><td>Beginning balance</td><td>$163,607</td><td>$156,925</td></tr><tr><td>Gross increases in unrecognized tax benefits – prior year tax positions</td><td>1,038</td><td>11,901</td></tr><tr><td>Gross decreases in unrecognized tax benefits – prior year tax positions</td><td>—</td><td>-4,154</td></tr><tr><td>Gross increases in unrecognized tax benefits – current year tax positions</td><td>23,771</td><td>32,420</td></tr><tr><td>Settlements with taxing authorities</td><td>-1,754</td><td>-29,101</td></tr><tr><td>Lapse of statute of limitations</td><td>-25,387</td><td>-3,825</td></tr><tr><td>Foreign exchange gains and losses</td><td>-807</td><td>-559</td></tr><tr><td>Ending balance</td><td>$160,468</td><td>$163,607</td></tr></table>
<table><tr><td></td><td colspan="3">Con Edison</td><td colspan="3">CECONY</td></tr><tr><td>(Millions of Dollars)</td><td>2016</td><td>2015</td><td>2014</td><td>2016</td><td>2015</td><td>2014</td></tr><tr><td>Balance at January 1,</td><td>$34</td><td>$34</td><td>$9</td><td>$2</td><td>$2</td><td>$—</td></tr><tr><td>Additions based on tax positions related to the current year</td><td>2</td><td>—</td><td>—</td><td>2</td><td>—</td><td>—</td></tr><tr><td>Additions based on tax positions of prior years</td><td>19</td><td>1</td><td>27</td><td>19</td><td>—</td><td>2</td></tr><tr><td>Reductions for tax positions of prior years</td><td>-13</td><td>—</td><td>-2</td><td>-2</td><td>—</td><td>—</td></tr><tr><td>Reductions from expiration of statute of limitations</td><td>—</td><td>-1</td><td>—</td><td>—</td><td>—</td><td>—</td></tr><tr><td>Settlements</td><td>—</td><td>—</td><td>—</td><td>—</td><td>—</td><td>—</td></tr><tr><td>Balance at December 31,</td><td>$42</td><td>$34</td><td>$34</td><td>$21</td><td>$2</td><td>$2</td></tr></table>
<table><tr><td>Cash</td><td>$27,961</td></tr><tr><td>Accounts receivable</td><td>17,811</td></tr><tr><td>Inventory</td><td>5,301</td></tr><tr><td>Property and equipment</td><td>4,710</td></tr><tr><td>Other tangible assets</td><td>1,082</td></tr><tr><td>Accrued taxes</td><td>-14,874</td></tr><tr><td>Accounts payable and accrued expenses</td><td>-6,641</td></tr><tr><td>Customer relationships</td><td>45,780</td></tr><tr><td>Business licenses</td><td>2,500</td></tr><tr><td>Trade names</td><td>2,110</td></tr><tr><td>Deferred taxes, net</td><td>-12,473</td></tr><tr><td>Goodwill</td><td>75,161</td></tr><tr><td>Purchase Price</td><td>$148,428</td></tr></table>

Question: What will Balance at December 31 in Con Edison be like in 2017 if it develops with the same increasing rate as current? (in millions)
Answer: 51.88235