definiens: means an amount ( not less than zero ) equal to the aggregate current Income Tax liabilities of the Conveyed Subsidiaries and their Subsidiaries ( which shall not be less th an zero in any jurisdiction ) for all taxable periods ( or porti ons thereof ) ending on or before the Closing Date f or which final Tax Returns have not been filed . The calculation of Seller Accrued Income Taxes shall ( i ) exclude any deferred Tax liabilities or deferred Tax assets and any amou nts in respect of speculative or contingent liabili ties for Tax, ( ii ) include estimated ( or other prepaid ) Income Ta x payments only to the extent that such payments ha ve the effect of reducing ( not below zero ) the particular current Income Tax liability in respect of which su ch payments were made, ( iii ) include Income Tax deductions or T ax refunds ( including for overpayments of estimated Taxes ), in each case, only to the extent such deductions or Tax refunds have the effect of reducing ( not below zero ) a particular current Income Tax liability to which th ey are relevant, ( iv ) be prepared in accordance wit h the past practice ( including reporting positions and account ing methods ) of the applicable Conveyed Subsidiary or its applicable Subsidiary in preparing Tax Returns for Income Taxes and ( v ) in the case of a Straddle Peri od, be determined in accordance with Section 6.5(d)(iii )