Uncertain Tax Positions The following is a reconciliation of the Company's beginning and ending amount of uncertain tax positions (in millions):
## Table 0 ##
The Company's liability for uncertain tax positions as of December 31, 2015, 2014, and 2013, includes $180 million, $154 million, and $141 million, respectively, related to amounts that would impact the effective tax rate if recognized.
It is possible that the amount of unrecognized tax benefits may change in the next twelve months; however, we do not expect the change to have a significant impact on our consolidated statements of income or consolidated balance sheets.
These changes may be the result of settlements of ongoing audits.
At this time, an estimate of the range of the reasonably possible outcomes within the twelve months cannot be made.
The Company recognizes interest and penalties related to uncertain tax positions in its provision for income taxes.
The Company accrued potential interest and penalties of $2 million, $4 million, and $2 million in 2015, 2014, and 2013, respectively.
The Company recorded a liability for interest and penalties of $33 million, $31 million, and $27 million as of December 31, 2015, 2014, and 2013, respectively.
The Company and its subsidiaries file income tax returns in their respective jurisdictions.
The Company has substantially concluded all U. S.  federal income tax matters for years through 2007.
Material U. S.  state and local income tax jurisdiction examinations have been concluded for years through 2005.
The Company has concluded income tax examinations in its primary non-U.
S.  jurisdictions through 2005.9.
Shareholders' Equity Distributable Reserves As a U. K.  incorporated company, the Company is required under U. K.  law to have available "distributable reserves" to make share repurchases or pay dividends to shareholders.
Distributable reserves may be created through the earnings of the U. K.  parent company and, amongst other methods, through a reduction in share capital approved by the English Companies Court.
Distributable reserves are not linked to a U. S.  GAAP reported amount (e. g. , retained earnings).
As of December 31, 2015 and 2014, the Company had distributable reserves in excess of $2.1 billion and $4.0 billion, respectively.
Ordinary Shares In April 2012, the Company's Board of Directors authorized a share repurchase program under which up to $5.0 billion of Class A Ordinary Shares may be repurchased ("2012 Share Repurchase Program").
In November 2014, the Company's Board of Directors authorized a new $5.0 billion share repurchase program in addition to the existing program ("2014 Share Repurchase Program" and, together, the "Repurchase Programs").
Under each program, shares may be repurchased through the open market or in privately negotiated transactions, based on prevailing market conditions, funded from available capital.
During 2015, the Company repurchased 16.0 million shares at an average price per share of $97.04 for a total cost of $1.6 billion under the Repurchase Programs.
During 2014, the Company repurchased 25.8 million shares at an average price per share of $87.18 for a total cost of $2.3 billion under the 2012 Share Repurchase Plan.
In August 2015, the $5 billion of Class A Ordinary Shares authorized under the 2012 Share Repurchase Program was exhausted.
At December 31, 2015, the remaining authorized amount for share repurchase under the 2014 Share Repurchase Program is $4.1 billion.
Under the Repurchase Programs, the Company repurchased a total of 78.1 million shares for an aggregate cost of $5.9 billion.
Table XIV Quarterly Supplemental Financial Data
## Table 1 ##
(1) FTE basis is a non-GAAP financial measure.
FTE basis is a performance measure used by management in operating the business that management believes provides investors with a more accurate picture of the interest margin for comparative purposes.
The Corporation believes that this presentation allows for comparison of amounts from both taxable and tax-exempt sources and is consistent with industry practices.
For more information on these performance measures and ratios, see Supplemental Financial Data on page 26 and for corresponding reconciliations to GAAP financial measures, see Statistical Table XVI.
## Table 2 ##
(1) Presents reconciliations of non-GAAP financial measures to GAAP financial measures.
We believe the use of these non-GAAP financial measures provides additional clarity in assessing the results of the Corporation.
Other companies may define or calculate these measures differently.
For more information on non-GAAP financial measures and ratios we use in assessing the results of the Corporation, see Supplemental Financial Data on page 26.
As of December 31, 2012, we: ?
owned and operated a petroleum refinery in El Dorado, Kansas, two refinery facilities located in Tulsa, Oklahoma, a refinery in Artesia, New Mexico that is operated in conjunction with crude oil distillation and vacuum distillation and other facilities situated 65 miles away in Lovington, New Mexico (collectively, the “Navajo Refinery”), a refinery located in Cheyenne, Wyoming and a refinery in Woods Cross, Utah (the “Woods Cross Refinery”); ?
owned and operated NK Asphalt Partners (“NK Asphalt”) which operates various asphalt terminals in Arizona and New Mexico; ?
owned Ethanol Management Company (“EMC”), a products terminal and blending facility near Denver, Colorado, and a 50% interest in Sabine Biofuels II, LLC (“Sabine Biofuels”), a biodiesel production facility located in Port Arthur, Texas; and ?
owned a 44% interest in HEP, a consolidated VIE, which includes our 2% general partner interest.
HEPowns and operates logistic assets consisting of petroleum product and crude oil pipelines and terminal, tankage and loading rack facilities that principally support our refining and marketing operations in the Mid-Continent, Southwest and Rocky Mountain regions of the United States and Alon USA, Inc. 's (“Alon”) refinery in Big Spring, Texas.
Additionally, HEPowns a 75% interest in UNEV Pipeline, L. L. C.  (“UNEV”), which owns a 12-inch refined products pipeline from Salt Lake City, Utah to Las Vegas, Nevada, together with terminal facilities in the Cedar City, Utah and North Las Vegas areas (the “UNEV Pipeline”) and a 25% interest in SLC Pipeline LLC (the “SLC Pipeline”), a 95-mile intrastate pipeline system that serves refineries in the Salt Lake City area.
Our operations are currently organized into two reportable segments, Refining and HEP.
The Refining segment includes the operations of our El Dorado, Tulsa, Navajo, Cheyenne and Woods Cross Refineries and NK Asphalt.
The HEPsegment involves all of the operations of HEP effective March 1, 2008 (date of reconsolidation).
The financial information about our segments is discussed in Note 21 “Segment Information” in the Notes to Consolidated Financial Statements.
REFINERY OPERATIONS Our refinery operations serve the Mid-Continent, Southwest and Rocky Mountain regions of the United States.
We own and operate five complex refineries having an aggregate crude capacity of 443,000 barrels per stream day.
Each of our refineries has the complexity to convert discounted, heavy and sour crude oils into a high percentage of gasoline, diesel and other high-value refined products.
For 2012, gasoline, diesel fuel, jet fuel and specialty lubricants (excluding volumes purchased for resale) represented 50%, 31%, 6% and 3%, respectively, of our total refinery sales volumes.
The tables presented below and elsewhere in this discussion of our refinery operations set forth information, including non-GAAP performance measures, about our refinery operations.
The cost of products and refinery gross and net operating margins do not include the effect of depreciation and amortization.
Reconciliations to amounts reported under GAAP are provided under “Reconciliations to Amounts Reported Under Generally Accepted Accounting Principles” following Item 7A of Part II of this Form 10-K.

<table><tr><td></td><td>2015</td><td>2014</td></tr><tr><td>Balance at January 1</td><td>$191</td><td>$164</td></tr><tr><td>Additions based on tax positions related to the current year</td><td>31</td><td>31</td></tr><tr><td>Additions for tax positions of prior years</td><td>53</td><td>10</td></tr><tr><td>Reductions for tax positions of prior years</td><td>-18</td><td>-6</td></tr><tr><td>Settlements</td><td>-32</td><td>—</td></tr><tr><td>Business combinations</td><td>—</td><td>5</td></tr><tr><td>Lapse of statute of limitations</td><td>-5</td><td>-11</td></tr><tr><td>Foreign currency translation</td><td>-2</td><td>-2</td></tr><tr><td>Balance at December 31</td><td>$218</td><td>$191</td></tr></table>
<table><tr><td></td><td colspan="4">2016 Quarters</td><td colspan="4">2015 Quarters</td></tr><tr><td>(Dollars in millions, except per share information)</td><td>Fourth</td><td>Third</td><td>Second</td><td>First</td><td>Fourth</td><td>Third</td><td>Second</td><td>First</td></tr><tr><td>Fully taxable-equivalent basis data<sup>-1</sup></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Net interest income<sup></sup></td><td>$10,526</td><td>$10,429</td><td>$10,341</td><td>$10,700</td><td>$9,911</td><td>$10,127</td><td>$9,739</td><td>$10,070</td></tr><tr><td>Total revenue, net of interest expense</td><td>20,224</td><td>21,863</td><td>21,509</td><td>21,005</td><td>19,807</td><td>21,219</td><td>21,262</td><td>21,566</td></tr><tr><td>Net interest yield</td><td>2.23%</td><td>2.23%</td><td>2.23%</td><td>2.33%</td><td>2.14%</td><td>2.19%</td><td>2.16%</td><td>2.26%</td></tr><tr><td>Efficiency ratio</td><td>65.08</td><td>61.66</td><td>62.73</td><td>70.54</td><td>70.73</td><td>65.70</td><td>65.65</td><td>73.39</td></tr></table>
<table><tr><td>(Dollars in millions, shares in thousands)</td><td>2016</td><td>2015</td><td>2014</td><td>2013</td><td>2012</td></tr><tr><td>Reconciliation of net interest income to net interest income on a fully taxable-equivalent basis</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Net interest income</td><td>$41,096</td><td>$38,958</td><td>$40,779</td><td>$40,719</td><td>$40,135</td></tr><tr><td>Fully taxable-equivalent adjustment</td><td>900</td><td>889</td><td>851</td><td>859</td><td>901</td></tr><tr><td>Net interest income on a fully taxable-equivalent basis</td><td>$41,996</td><td>$39,847</td><td>$41,630</td><td>$41,578</td><td>$41,036</td></tr><tr><td>Reconciliation of total revenue, net of interest expense to total revenue, net of interest expense on a fully taxable-equivalent basis</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Total revenue, net of interest expense</td><td>$83,701</td><td>$82,965</td><td>$85,894</td><td>$87,502</td><td>$82,798</td></tr><tr><td>Fully taxable-equivalent adjustment</td><td>900</td><td>889</td><td>851</td><td>859</td><td>901</td></tr><tr><td>Total revenue, net of interest expense on a fully taxable-equivalent basis</td><td>$84,601</td><td>$83,854</td><td>$86,745</td><td>$88,361</td><td>$83,699</td></tr><tr><td>Reconciliation of income tax expense (benefit) to income tax expense (benefit) on a fully taxable-equivalent basis</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Income tax expense (benefit)</td><td>$7,247</td><td>$6,234</td><td>$2,443</td><td>$4,194</td><td>$-1,320</td></tr><tr><td>Fully taxable-equivalent adjustment</td><td>900</td><td>889</td><td>851</td><td>859</td><td>901</td></tr><tr><td>Income tax expense (benefit) on a fully taxable-equivalent basis</td><td>$8,147</td><td>$7,123</td><td>$3,294</td><td>$5,053</td><td>$-419</td></tr><tr><td>Reconciliation of average common shareholders’ equity to average tangible common shareholders’ equity</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Common shareholders’ equity</td><td>$241,621</td><td>$230,173</td><td>$222,907</td><td>$218,340</td><td>$216,999</td></tr><tr><td>Goodwill</td><td>-69,750</td><td>-69,772</td><td>-69,809</td><td>-69,910</td><td>-69,974</td></tr><tr><td>Intangible assets (excluding MSRs)</td><td>-3,382</td><td>-4,201</td><td>-5,109</td><td>-6,132</td><td>-7,366</td></tr><tr><td>Related deferred tax liabilities</td><td>1,644</td><td>1,852</td><td>2,090</td><td>2,328</td><td>2,593</td></tr><tr><td>Tangible common shareholders’ equity</td><td>$170,133</td><td>$158,052</td><td>$150,079</td><td>$144,626</td><td>$142,252</td></tr><tr><td>Reconciliation of average shareholders’ equity to average tangible shareholders’ equity</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Shareholders’ equity</td><td>$266,277</td><td>$251,981</td><td>$238,317</td><td>$233,819</td><td>$235,681</td></tr><tr><td>Goodwill</td><td>-69,750</td><td>-69,772</td><td>-69,809</td><td>-69,910</td><td>-69,974</td></tr><tr><td>Intangible assets (excluding MSRs)</td><td>-3,382</td><td>-4,201</td><td>-5,109</td><td>-6,132</td><td>-7,366</td></tr><tr><td>Related deferred tax liabilities</td><td>1,644</td><td>1,852</td><td>2,090</td><td>2,328</td><td>2,593</td></tr><tr><td>Tangible shareholders’ equity</td><td>$194,789</td><td>$179,860</td><td>$165,489</td><td>$160,105</td><td>$160,934</td></tr><tr><td>Reconciliation of year-end common shareholders’ equity to year-end tangible common shareholders’ equity</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Common shareholders’ equity</td><td>$241,620</td><td>$233,903</td><td>$224,167</td><td>$219,124</td><td>$218,194</td></tr><tr><td>Goodwill</td><td>-69,744</td><td>-69,761</td><td>-69,777</td><td>-69,844</td><td>-69,976</td></tr><tr><td>Intangible assets (excluding MSRs)</td><td>-2,989</td><td>-3,768</td><td>-4,612</td><td>-5,574</td><td>-6,684</td></tr><tr><td>Related deferred tax liabilities</td><td>1,545</td><td>1,716</td><td>1,960</td><td>2,166</td><td>2,428</td></tr><tr><td>Tangible common shareholders’ equity</td><td>$170,432</td><td>$162,090</td><td>$151,738</td><td>$145,872</td><td>$143,962</td></tr><tr><td>Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Shareholders’ equity</td><td>$266,840</td><td>$256,176</td><td>$243,476</td><td>$232,475</td><td>$236,962</td></tr><tr><td>Goodwill</td><td>-69,744</td><td>-69,761</td><td>-69,777</td><td>-69,844</td><td>-69,976</td></tr><tr><td>Intangible assets (excluding MSRs)</td><td>-2,989</td><td>-3,768</td><td>-4,612</td><td>-5,574</td><td>-6,684</td></tr><tr><td>Related deferred tax liabilities</td><td>1,545</td><td>1,716</td><td>1,960</td><td>2,166</td><td>2,428</td></tr><tr><td>Tangible shareholders’ equity</td><td>$195,652</td><td>$184,363</td><td>$171,047</td><td>$159,223</td><td>$162,730</td></tr><tr><td>Reconciliation of year-end assets to year-end tangible assets</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Assets</td><td>$2,187,702</td><td>$2,144,287</td><td>$2,104,539</td><td>$2,102,064</td><td>$2,209,981</td></tr><tr><td>Goodwill</td><td>-69,744</td><td>-69,761</td><td>-69,777</td><td>-69,844</td><td>-69,976</td></tr><tr><td>Intangible assets (excluding MSRs)</td><td>-2,989</td><td>-3,768</td><td>-4,612</td><td>-5,574</td><td>-6,684</td></tr><tr><td>Related deferred tax liabilities</td><td>1,545</td><td>1,716</td><td>1,960</td><td>2,166</td><td>2,428</td></tr><tr><td>Tangible assets</td><td>$2,116,514</td><td>$2,072,474</td><td>$2,032,110</td><td>$2,028,812</td><td>$2,135,749</td></tr></table>

Question: Which section is Net interest income the lowest in 2016?
Answer: Second