interest and penalties with respect to unrecognized tax benefits were $ 3 million as of each of december 31 , 2015 and 2014 . during 2013 , the company recorded a reduction of $ 14 million to its liability for uncertain tax positions related to a change approved by the irs for the allocation of interest costs to long term construction contracts at ingalls . this change was made on a prospective basis only and did not impact the tax returns filed for years prior to 2013 . the following table summarizes the tax years that are either currently under examination or remain open under the applicable statute of limitations and subject to examination by the major tax jurisdictions in which the company operates: .

Table:
jurisdiction united states | jurisdiction 2007 | jurisdiction - | 2014
california | 2010 | - | 2014
louisiana | 2012 | - | 2014
mississippi | 2012 | - | 2014
virginia | 2012 | - | 2014
although the company believes it has adequately provided for all uncertain tax positions , amounts asserted by taxing authorities could be greater than the company's accrued position .
accordingly , additional provisions for federal and state income tax related matters could be recorded in the future as revised estimates are made or the underlying matters are effectively settled or otherwise resolved .
conversely , the company could settle positions with the tax authorities for amounts lower than have been accrued .
the company believes that it is reasonably possible that during the next 12 months the company's liability for uncertain tax positions may decrease by approximately $ 2 million due to statute of limitation expirations .
the company recognizes accrued interest and penalties related to uncertain tax positions in income tax expense .
the irs is currently conducting an examination of northrop grumman's consolidated tax returns , of which hii was part , for the years 2007 through the spin-off .
during 2013 the company entered into the pre-compliance assurance process with the irs for years 2011 and 2012 .
the company is part of the irs compliance assurance process program for the 2014 , 2015 , and 2016 tax years .
open tax years related to state jurisdictions remain subject to examination .
as of march 31 , 2011 , the date of the spin-off , the company's liability for uncertain tax positions was approximately $ 4 million , net of federal benefit , which related solely to state income tax positions .
under the terms of the separation agreement , northrop grumman is obligated to reimburse hii for any settlement liabilities paid by hii to any government authority for tax periods prior to the spin-off , which include state income taxes .
as a result , the company recorded in other assets a reimbursement receivable of approximately $ 4 million , net of federal benefit , related to uncertain tax positions for state income taxes as of the date of the spin-off .
in 2014 , the statute of limitations expired for the $ 4 million liability related to state uncertain tax positions as of the spin-off date .
accordingly , the $ 4 million liability and the associated reimbursement receivable were written off .
on september 13 , 2013 , the treasury department and the internal revenue service issued final regulations regarding the deduction and capitalization of amounts paid to acquire , produce , improve , or dispose of tangible personal property .
these regulations are generally effective for tax years beginning on or after january 1 , 2014 .
the application of these regulations did not have a material impact on the company's consolidated financial statements .
deferred income taxes - deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and for income tax purposes .
such amounts are classified in the consolidated statements of financial position as current or non-current assets or liabilities based upon the classification of the related assets and liabilities. .

Question: what is the percent of the average unrecognized tax benefits fro 2014 and 2015 to the recorded reduction in its liability for uncertain tax positions based on the approved irs allocation
Answer: 21.4%
Calculation: divide(const_3, 14)