KIMCO REALTY CORPORATION AND SUBSIDIARIES NOTES TO CONSOLIDATED FINANCIAL STATEMENTS, continued Uncertain Tax Positions: The Company is subject to income tax in certain jurisdictions outside the U. S. , principally Canada and Mexico.
The statute of limitations on assessment of tax varies from three to seven years depending on the jurisdiction and tax issue.
Tax returns filed in each jurisdiction are subject to examination by local tax authorities.
The Company is currently under audit by the Canadian Revenue Agency, Mexican Tax Authority and the U. S.  Internal Revenue Service (“IRS”).
In October 2011, the IRS issued a notice of proposed adjustment, which proposes pursuant to Section 482 of the Code, to disallow a capital loss claimed by KRS on the disposition of common shares of Valad Property Ltd. , an Australian publicly listed company.
Because the adjustment is being made pursuant to Section 482 of the Code, the IRS believes it can assert a 100 percent “penalty” tax pursuant to Section 857(b)(7) of the Code and disallow the capital loss deduction.
The notice of proposed adjustment indicates the IRS’ intention to impose the 100 percent “penalty” tax on the Company in the amount of $40.9 million and disallowing the capital loss claimed by KRS.
The Company and its outside counsel have considered the IRS’ assessment and believe that there is sufficient documentation establishing a valid business purpose for the transfer, including recent case history showing support for similar positions.
Accordingly, the Company strongly disagrees with the IRS’ position on the application of Section 482 of the Code to the disposition of the shares, the imposition of the 100 percent penalty tax and the simultaneous assertion of the penalty tax and disallowance of the capital loss deduction.
The Company received a Notice of Proposed Assessment and filed a written protest and requested an IRS Appeals Office conference.
An appeals hearing was attended by Management and its attorneys, the IRS Compliance Group and an IRS Appeals Officer in November, 2014, at which time IRS Compliance presented arguments in support of their position, as noted herein.
Management and its attorneys presented rebuttal arguments in support of its position.
The matter is currently under consideration by the Appeals Officer.
The Company intends to vigorously defend its position in this matter and believes it will prevail.
Resolutions of these audits are not expected to have a material effect on the Company’s financial statements.
During 2013, the Company early adopted ASU 2013-11 prospectively and reclassified a portion of its reserve for uncertain tax positions.
The reserve for uncertain tax positions included amounts related to the Company’s Canadian operations.
The Company has unrecognized tax benefits reported as deferred tax assets and are available to settle adjustments made with respect to the Company’s uncertain tax positions in Canada.
The Company reduced its reserve for uncertain tax positions by $12.3 million associated with its Canadian operations and reduced its deferred tax assets in accordance with ASU 2013-11.
The Company does not believe that the total amount of unrecognized tax benefits as of December 31, 2014, will significantly increase or decrease within the next 12 months.
As of December 31, 2014, the Company’s Canadian uncertain tax positions, which reduce its deferred tax assets, aggregated $10.4 million.
The liability for uncertain tax benefits principally consists of estimated foreign, federal and state income tax liabilities in years for which the statute of limitations is open.
Open years range from 2008 through 2014 and vary by jurisdiction and issue.
The aggregate changes in the balance of unrecognized tax benefits for the years ended December 31, 2014 and 2013 were as follows (in thousands):
## Table 0 ##
(a) This amount was reclassified against the related deferred tax asset relating to the Company’s early adoption of ASU 2013-11 as discussed above.
LENNAR CORPORATION AND SUBSIDIARIES NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—(Continued)
## Table 1 ##
At November 30, 2003, the Company’s equity interest in these Partnerships did not exceed 50%.
The Company’s partners generally are unrelated homebuilders, land sellers or other real estate entities.
The Partnerships follow accounting principles generally accepted in the United States of America.
The Company shares in the profits and losses of these Partnerships generally in accordance with its ownership interests.
In many instances, the Company is appointed as the day-to-day manager of the Partnerships and receives fees for performing this function.
During 2003, 2002 and 2001, the Company received management fees and reimbursement of expenses from the Partnerships totaling $39.0 million, $29.2 million and $26.1 million, respectively.
In determining its share of the Partnerships’ net earnings, the Company does not include in its income its pro rata share of partnership earnings resulting from land sales to its homebuilding divisions.
Instead, the Company accounts for those earnings as a reduction of the cost of purchasing the land from the partnerships.
This in effect defers recognition of the Company’s share of the partnership earnings relating to these sales until a home is delivered and title passes to a homebuyer.
The Company and/or its partners sometimes obtain options or enter into other arrangements under which the Company can purchase portions of the land held by the Partnerships.
Option prices are generally negotiated prices that approximate fair value when the options are purchased.
During 2003, 2002 and 2001, $460.5 million, $419.3 million and $232.6 million, respectively, of the Partnerships’ revenues were from land sales to the Company.
In some instances, the Company and/or its partners have provided varying levels of guarantees of debt of unconsolidated partnerships.
At November 30, 2003, the Company had recourse guarantees of $88.7 million and limited maintenance guarantees of $111.6 million of debt of unconsolidated partnerships.
When the Company and/or its partners provide a guarantee, the partnership generally receives more favorable terms from its lenders than would otherwise be available to it.
The limited maintenance guarantees only apply if a partnership defaults on its loan arrangements and the carrying value of the collateral (generally land and improvements) is less than a specified percentage of the loan balance.
If the Company is required to make a payment under a limited maintenance guarantee to bring the carrying value of the collateral above the specified percentage of the loan balance, the payment would constitute a capital contribution or loan to the unconsolidated partnership and increase the Company’s share of any funds the unconsolidated partnership distributes.
There were no assets held as collateral that, upon the occurrence of any triggering event or condition under a guarantee, the Company could obtain and liquidate to recover all or a portion of the amounts paid under a guarantee.
In November 2003, the Company and LNR each contributed its 50% interests in certain of its jointly-owned unconsolidated partnerships that had significant assets to a new limited liability company named LandSource Communities Development LLC (“LandSource”), in exchange for 50% interests in LandSource.
In addition, in July 2003, the Company and LNR formed, and obtained 50% interests in, NWHL Investment, LLC (“NWHL”), which agreed to purchase, and in January 2004 completed the purchase, of The Newhall Land and Farming Company (“Newhall”) for a total of approximately $1 billion.
Newhall’s primary business is developing two master-planned communities in Los Angeles County, California.
The Company and LNR each contributed approximately $200 million to NWHL, and LandSource and NWHL jointly obtained $600 million of bank financing, of which $400 million was used in connection with the acquisition of Newhall (the remainder of the acquisition price was paid with proceeds of a sale of income-producing properties from Newhall to LNR for $217 million at the closing of the transaction).
The Company agreed to purchase 687 homesites and obtained options to purchase 623 homesites from the venture.
The Company is not obligated with regard to the borrowings by LandSource and NWHL, except that the Company and LNR have made limited maintenance guarantees and
LENNAR CORPORATION AND SUBSIDIARIES NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—(Continued) are granted.
Each stock option and stock appreciation right will expire on a date determined at the time of the grant, but not more than 10 years after the date of the grant.
At November 30, 2003, a combined total of 1,036,200 shares of Class A and Class B restricted stock (adjusted for the January 2004 two-for-one stock split) were outstanding under the Plan.
The stock was valued based on its market price on the date of the grant.
The grants vest over 5 years from the date of issuance.
Unearned compensation arising from the restricted stock grants is amortized to expense over the period of the restrictions and is shown as a reduction of stockholders’ equity in the consolidated balance sheets.
The Lennar Corporation 1997 Stock Option Plan (the “1997 Plan”) provided for the granting of Class A stock options and stock appreciation rights to key employees of the Company to purchase shares at prices not less than market value of the common stock on the date of the grant.
No options granted under the 1997 Plan may be exercisable until at least six months after the date of the grant.
Thereafter, exercises are permitted in installments determined when options are granted.
Each stock option and stock appreciation right granted will expire on a date determined at the time of the grant, but not more than 10 years after the date of the grant.
The Lennar Corporation 1991 Stock Option Plan (the “1991 Plan”) provided for the granting of options to certain key employees of the Company to purchase Class A shares at prices not less than market value of the common stock on the date of the grant.
No options granted under the 1991 Plan may be exercisable until at least six months after the date of the grant.
Thereafter, exercises are permitted in installments determined when options are granted.
Each stock option granted will expire on a date determined at the time of the grant, but not more than 10 years after the date of the grant.
A summary of the Company’s stock option activity for the years ended November 30, 2003, 2002 and 2001 (adjusted for the January 2004 two-for-one stock split) is as follows:
## Table 2 ##
* Represents options for Class B common stock which were issued as a result of anti-dilution provisions with regard to unexercised Class A stock options as of the date of the April 2003 10% Class B stock distribution.

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td>201 4</td><td>2013</td></tr><tr><td>Balance, beginning of year</td><td>$4,590</td><td>$16,890</td></tr><tr><td>Increases for tax positions related to current year</td><td>59</td><td>15</td></tr><tr><td>Reduction due to adoption of ASU 2013-11(a)</td><td>-</td><td>-12,315</td></tr><tr><td>Balance, end of year</td><td>$4,649</td><td>$4,590</td></tr></table>
<table><tr><td></td><td colspan="3"> Years Ended November 30, </td></tr><tr><td></td><td> 2003 </td><td> 2002 </td><td> 2001 </td></tr><tr><td></td><td colspan="3"> (In thousands)</td></tr><tr><td>Revenues</td><td>$1,314,674</td><td>939,847</td><td>903,293</td></tr><tr><td>Costs and expenses</td><td>938,981</td><td>780,093</td><td>761,704</td></tr><tr><td>Net earnings of unconsolidated partnerships</td><td>$375,693</td><td>159,754</td><td>141,589</td></tr><tr><td>Company’s share of net earnings</td><td>$81,937</td><td>42,651</td><td>27,051</td></tr></table>
<table><tr><td></td><td colspan="2"> 2003 </td><td colspan="2"> 2002 </td><td colspan="2"> 2001 </td></tr><tr><td></td><td>Stock Options</td><td> Weighted Average Exercise Price </td><td>Stock Options</td><td> Weighted Average Exercise Price </td><td>Stock Options</td><td> Weighted Average Exercise Price </td></tr><tr><td>Outstanding, beginning of year</td><td>4,827,348</td><td>$15.98</td><td>5,731,512</td><td>$11.57</td><td>6,957,366</td><td>$8.34</td></tr><tr><td>Grants</td><td>2,636,000</td><td>$28.36</td><td>1,100,000</td><td>$26.37</td><td>1,583,200</td><td>$18.74</td></tr><tr><td>Other *</td><td>694,824</td><td>$—</td><td>—</td><td>$—</td><td>—</td><td>$—</td></tr><tr><td>Terminations</td><td>-19,250</td><td>$22.74</td><td>-124,024</td><td>$16.01</td><td>-202,778</td><td>$14.67</td></tr><tr><td>Exercises</td><td>-1,477,954</td><td>$12.27</td><td>-1,880,140</td><td>$8.60</td><td>-2,606,276</td><td>$7.07</td></tr><tr><td>Outstanding, end of year</td><td>6,660,968</td><td>$20.01</td><td>4,827,348</td><td>$15.98</td><td>5,731,512</td><td>$11.57</td></tr><tr><td>Exercisable, end of year</td><td>745,336</td><td>$12.96</td><td>936,074</td><td>$12.79</td><td>1,497,624</td><td>$7.80</td></tr><tr><td>Available for grant, end of year</td><td>9,821,000</td><td></td><td>3,394,600</td><td></td><td>4,433,000</td><td></td></tr><tr><td>Weighted average fair value per share of options granted during the year under SFAS No. 123</td><td></td><td>$8.65</td><td></td><td>$11.72</td><td></td><td>$9.21</td></tr></table>

Question: what is the proportion of dollars at the beginning of both combined years to dollars at end of both combined years?
Answer: 2.32493
Reasoning program: add(4590,16890), add(4649,4590), divide(#0,#1)