Albemarle Corporation and Subsidiaries NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 81 tax position taken, or expected to be taken, in a tax return.
The accounting for uncertain tax provisions also provides guidance on derecognition, classification, interest and penalties, accounting in interim periods, disclosure, and transition.
As a result of the implementation of this accounting guidance, we recognized an increase of approximately $4.8 million in the liability related to uncertain tax positions, which was accounted for as a reduction to retained earnings as of January 1, 2007.
The liabilities related to uncertain tax positions, inclusive of interest and penalties, were $22.3 million and $81.3 million at December 31, 2009 and 2008, respectively, and are reported in "Other Noncurrent Liabilities" as provided in Note 13.
These liabilities at December 31, 2009 and 2008 were reduced by $14.9 million and $39.9 million, respectively, for offsetting benefits from the corresponding effects of potential transfer pricing adjustments, state income taxes and rate arbitrage related to foreign structure.
These offsetting benefits yielded assets of the same amounts at December 31, 2009 and 2008, respectively, and are recorded in “Other Assets” as provided in Note 9.
The resulting net liabilities of $8.5 million and $37.6 million at December 31, 2009 and 2008, respectively, if recognized and released, would favorably affect earnings.
The liabilities related to uncertain tax positions include interest and penalties of $0.9 million and $3.8 million at December 31, 2009 and 2008, respectively, and are recognized as components of income taxes.
The liabilities related to uncertain tax positions, exclusive of interest, were $23.4 million and $77.5 million at December 31, 2009 and 2008, respectively.
The following is a reconciliation of our total gross liability related to uncertain tax positions for 2009 and 2008 (in thousands):
## Table 0 ##
We are subject to income taxes in the U. S.  and numerous foreign jurisdictions.
We are no longer subject to U. S.  federal income tax examinations by tax authorities for years before 2008 since the IRS has completed a review of our income tax returns through 2007.
With respect to jurisdictions outside the U. S. , we are no longer subject to income tax audits for years before 2002.
During 2009, we completed the tax audits for the following tax jurisdictions and respective tax years: Germany, 2002 through 2005 and Belgium, 2007 and 2008 for one of our Belgian companies.
During 2008, we completed tax audits in the following tax jurisdictions and respective tax years: Belgium, 2005 through 2006; United Kingdom, 2003; and the Netherlands, 2004 through 2005.
No significant tax was assessed for these audits.
We were informed in January 2010 that the Belgian tax authorities would commence an audit of another of our Belgian companies for the years 2007 and 2008.
While we believe we have adequately provided for all tax positions, amounts asserted by taxing authorities could be greater than our accrued position.
Accordingly, additional provisions on federal and foreign tax-related matters could be recorded in the future as revised estimates are made or the underlying matters are settled or otherwise resolved.
Since the timing of resolutions and/or closure of tax audits is uncertain, it is difficult to predict with certainty the range of reasonably possible significant increases or decreases in the liability related to uncertain tax positions that may occur within the next twelve months.
Our current view is that it is reasonably possible that we could record a decrease in the liability related to uncertain tax positions, relating to a number of issues, up to approximately $1.0 million as a result of settlements with taxing authorities and closure of tax statutes.
The following tables summarize the key characteristics of Citi’s credit derivative portfolio by counterparty and derivative form as of December31, 2009 and December31, 2008:
## Table 1 ##
The fair values shown are prior to the application of any netting agreements, cash collateral, and market or credit value adjustments.
Citigroup actively participates in trading a variety of credit derivatives products as both an active two-way market-maker for clients and to manage credit risk.
The majority of this activity was transacted with other financial intermediaries, including both banks and broker-dealers.
Citigroup generally has a mismatch between the total notional amounts of protection purchased and sold and it may hold the reference assets directly, rather than entering into offsetting credit derivative contracts as and when desired.
The open risk exposures from credit derivative contracts are largely matched after certain cash positions in reference assets are considered and after notional amounts are adjusted, either to a duration-based equivalent basis or to reflect the level of subordination in tranched structures.
Citi actively monitors its counterparty credit risk in credit derivative contracts.
Approximately 85% and 88% of the gross receivables are from counterparties with which Citi maintains collateral agreements as of December 31, 2009 and 2008, respectively.
A majority of Citi’s top 15 counterparties (by receivable balance owed to the company) are banks, financial institutions or other dealers.
Contracts with these counterparties do not include ratings-based termination events.
However, counterparty rating downgrades may have an incremental effect by lowering the threshold at which Citigroup may call for additional collateral.
A number of the remaining significant counterparties are monolines (which have CVA as shown above).
and smaller increases in other categories of noninterest income, offset by decreases of $3 million each in service charges on deposit accounts (proforma) and letter of credit fees.
Noninterest expenses reflected increases of $13 million in allocated corporate overhead, $6 million in salaries and benefits expense, $4 million each in outside processing fee expense (proforma) and restructuring charges as well as smaller increases in other categories of noninterest expenses, partially offset by a $4 million decrease in FDIC insurance expense.
Additionally, the increase in noninterest expenses reflected the impact of a $3 million benefit in 2017 due to a favorable litigation-related settlement.
The Texas market's net income increased $54 million to $229 million.
Average loans decreased $148 million and average deposits decreased $632 million.
Net interest income increased $24 million to $475 million.
An increase in loan income of $68 million was partially offset by increases of $5 million in deposit costs and $40 million in allocated net FTP charges.
The FTP allocation reflected increases in funding charges and in crediting rates on deposits as a result of higher short-term rates.
The provision for credit losses was impacted by a $19 million decrease in provision benefit to $53 million, primarily due to improved credit quality and a large decrease in Energy loans in 2017.
Net credit-related charge-offs decreased $34 million to $12 million, primarily reflecting decreases in Energy and general Middle Market.
Including the Topic 606 proforma reduction of $6 million to the prior year, noninterest income increased $5 million and noninterest expenses decreased $4 million.
Noninterest income was primarily impacted by a $3 million increase in card fees (proforma).
The decline in noninterest expenses primarily reflected decreases of $4 million in allocated corporate overhead and $3 million in FDIC insurance expense, partially offset by a $2 million increase in outside processing fee expense (proforma).
Other Markets' net income increased $95 million to $280 million.
Average loans increased $227 million and average deposits increased $267 million.
Net interest income increased $36 million to $352 million.
An increase in loan income of $70 million was partially offset by a $13 million increase in deposit costs and a $21 million increase in allocated net FTP charges.
The FTP allocation reflected an increase in funding charges as well as increases in crediting rates on deposits as a result of higher short-term rates.
The provision for credit losses decreased $39 million to a $6 million benefit, with most of the decreases in Corporate Banking, Small Business as well as Technology and Life Sciences.
Net credit-related charge-offs decreased $9 million to $5 million, primarily reflecting decreases in Technology and Life Sciences as well as Small Business.
Including the Topic 606 proforma reduction of $92 million to the prior year, noninterest income increased $28 million and noninterest expenses increased $18 million.
Noninterest income was primarily impacted by increases of $15 million in fiduciary income and $13 million in card fees (proforma).
Noninterest expenses primarily reflected increases of $11 million in salaries and benefits expense and $10 million in allocated corporate overhead, partially offset by a $4 million decrease in outside processing fee expense (proforma).
Net income for the Finance & Other category increased $118 million to $25 million, primarily reflecting the $120 million change in discrete tax items and an increase in FTP revenue as a result of higher rates charged to the market segments under the Corporation's internal FTP methodology, partially offset by a $15 million loss, net of tax, due to repositioning the securities portfolio.
The following table lists the Corporation's banking centers by geographic market segment.
## Table 2 ##
Management’s Discussion and Analysis Sensitivity Measures Certain portfolios and individual positions are not included in VaR because VaR is not the most appropriate risk measure.
Other sensitivity measures we use to analyze market risk are described below.10% Sensitivity Measures.
The table below presents market risk for inventory positions that are not included in VaR.
The market risk of these positions is determined by estimating the potential reduction in net revenues of a 10% decline in the underlying asset value.
Equity positions below relate to private and restricted public equity securities, including interests in funds that invest in corporate equities and real estate and interests in hedge funds, which are included in “Financial instruments owned, at fair value.
” Debt positions include interests in funds that invest in corporate mezzanine and senior debt instruments, loans backed by commercial and residential real estate, corporate bank loans and other corporate debt, including acquired portfolios of distressed loans.
These debt positions are included in “Financial instruments owned, at fair value.
” See Note 6 to the consolidated financial statements for further information about cash instruments.
These measures do not reflect diversification benefits across asset categories or across other market risk measures.

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td>2009</td><td>2008</td></tr><tr><td>Balance at January 1</td><td>$77,548</td><td>$100,999</td></tr><tr><td>Additions for tax positions related to prior years</td><td>5,082</td><td>16,399</td></tr><tr><td>Reductions for tax positions related to prior years</td><td>-48,054</td><td>-31,924</td></tr><tr><td>Additions for tax positions related to current year</td><td>1,495</td><td>12,085</td></tr><tr><td>Settlements</td><td>-12,627</td><td>-4,417</td></tr><tr><td>Lapses in statutes of limitations</td><td>-28</td><td>-15,594</td></tr><tr><td>Balance at December 31</td><td>$23,416</td><td>$77,548</td></tr></table>
<table><tr><td>2009</td><td></td><td rowspan="2">Fair values Payable</td><td></td><td rowspan="2">Notionals Guarantor</td></tr><tr><td>In millions of dollars</td><td>Receivable</td><td>Beneficiary</td></tr><tr><td>By industry/counterparty</td><td></td><td></td><td></td><td></td></tr><tr><td>Bank</td><td>$52,383</td><td>$50,778</td><td>$872,523</td><td>$807,484</td></tr><tr><td>Broker-dealer</td><td>23,241</td><td>22,932</td><td>338,829</td><td>340,949</td></tr><tr><td>Monoline</td><td>5,860</td><td>—</td><td>10,018</td><td>33</td></tr><tr><td>Non-financial</td><td>339</td><td>371</td><td>13,437</td><td>13,221</td></tr><tr><td>Insurance and other financial institutions</td><td>10,969</td><td>8,343</td><td>98,155</td><td>52,366</td></tr><tr><td>Total by industry/counterparty</td><td>$92,792</td><td>$82,424</td><td>$1,332,962</td><td>$1,214,053</td></tr><tr><td>By instrument</td><td></td><td></td><td></td><td></td></tr><tr><td>Credit default swaps and options</td><td>$91,625</td><td>$81,174</td><td>$1,305,724</td><td>$1,213,208</td></tr><tr><td>Total return swaps and other</td><td>1,167</td><td>1,250</td><td>27,238</td><td>845</td></tr><tr><td>Total byinstrument</td><td>$92,792</td><td>$82,424</td><td>$1,332,962</td><td>$1,214,053</td></tr><tr><td>2008</td><td></td><td>Fair values</td><td></td><td>Notionals</td></tr><tr><td>In millions of dollars</td><td>Receivable</td><td>Payable</td><td>Beneficiary</td><td>Guarantor</td></tr><tr><td>By industry/counterparty</td><td></td><td></td><td></td><td></td></tr><tr><td>Bank</td><td>$128,042</td><td>$121,811</td><td>$996,248</td><td>$943,949</td></tr><tr><td>Broker-dealer</td><td>59,321</td><td>56,858</td><td>403,501</td><td>365,664</td></tr><tr><td>Monoline</td><td>6,886</td><td>91</td><td>9,973</td><td>139</td></tr><tr><td>Non-financial</td><td>4,874</td><td>2,561</td><td>5,608</td><td>7,540</td></tr><tr><td>Insurance and other financial institutions</td><td>29,228</td><td>22,388</td><td>180,354</td><td>125,988</td></tr><tr><td>Total by industry/counterparty</td><td>$228,351</td><td>$203,709</td><td>$1,595,684</td><td>$1,443,280</td></tr><tr><td>By instrument</td><td></td><td></td><td></td><td></td></tr><tr><td>Credit default swaps and options</td><td>$221,159</td><td>$203,220</td><td>$1,560,222</td><td>$1,441,375</td></tr><tr><td>Total return swaps and other</td><td>7,192</td><td>489</td><td>35,462</td><td>1,905</td></tr><tr><td>Total byinstrument</td><td>$228,351</td><td>$203,709</td><td>$1,595,684</td><td>$1,443,280</td></tr></table>
<table><tr><td>December 31</td><td>2018</td><td>2017</td><td>2016</td></tr><tr><td>Michigan</td><td>193</td><td>194</td><td>209</td></tr><tr><td>Texas</td><td>122</td><td>122</td><td>127</td></tr><tr><td>California</td><td>96</td><td>97</td><td>97</td></tr><tr><td>Other Markets:</td><td></td><td></td><td></td></tr><tr><td>Arizona</td><td>17</td><td>17</td><td>17</td></tr><tr><td>Florida</td><td>7</td><td>7</td><td>7</td></tr><tr><td>Canada</td><td>1</td><td>1</td><td>1</td></tr><tr><td>Total Other Markets</td><td>25</td><td>25</td><td>25</td></tr><tr><td>Total</td><td>436</td><td>438</td><td>458</td></tr></table>

Question: Does the value of By instrument:Credit default swaps and options in 2009 greater than that in 2008 for Receivable?
Answer: no