united parcel service , inc . and subsidiaries notes to consolidated financial statements 2014 ( continued ) the following table summarizes the activity related to our unrecognized tax benefits ( in millions ) : .

Table:
balance at january 1 2007 | $ 373
additions for tax positions of the current year | 13
additions for tax positions of prior years | 34
reductions for tax positions of prior years for: | 
changes in judgment or facts | -12 ( 12 )
settlements during the period | -49 ( 49 )
lapses of applicable statute of limitations | -4 ( 4 )
balance at december 31 2007 | $ 355
as of december 31 , 2007 , the total amount of gross unrecognized tax benefits that , if recognized , would affect the effective tax rate was $ 134 million .
we also had gross recognized tax benefits of $ 567 million recorded as of december 31 , 2007 associated with outstanding refund claims for prior tax years .
therefore , we had a net receivable recorded with respect to prior year income tax matters in the accompanying balance sheets .
our continuing practice is to recognize interest and penalties associated with income tax matters as a component of income tax expense .
related to the uncertain tax benefits noted above , we accrued penalties of $ 5 million and interest of $ 36 million during 2007 .
as of december 31 , 2007 , we have recognized a liability for penalties of $ 6 million and interest of $ 75 million .
additionally , we have recognized a receivable for interest of $ 116 million for the recognized tax benefits associated with outstanding refund claims .
we file income tax returns in the u.s .
federal jurisdiction , most u.s .
state and local jurisdictions , and many non-u.s .
jurisdictions .
as of december 31 , 2007 , we had substantially resolved all u.s .
federal income tax matters for tax years prior to 1999 .
in the third quarter of 2007 , we entered into a joint stipulation to dismiss the case with the department of justice , effectively withdrawing our refund claim related to the 1994 disposition of a subsidiary in france .
the write-off of previously recognized tax receivable balances associated with the 1994 french matter resulted in a $ 37 million increase in income tax expense for the quarter .
however , this increase was offset by the impact of favorable developments with various other u.s .
federal , u.s .
state , and non-u.s .
contingency matters .
in february 2008 , the irs completed its audit of the tax years 1999 through 2002 with only a limited number of issues that will be considered by the irs appeals office by 2009 .
the irs is in the final stages of completing its audit of the tax years 2003 through 2004 .
we anticipate that the irs will conclude its audit of the 2003 and 2004 tax years by 2009 .
with few exceptions , we are no longer subject to u.s .
state and local and non-u.s .
income tax examinations by tax authorities for tax years prior to 1999 , but certain u.s .
state and local matters are subject to ongoing litigation .
a number of years may elapse before an uncertain tax position is audited and ultimately settled .
it is difficult to predict the ultimate outcome or the timing of resolution for uncertain tax positions .
it is reasonably possible that the amount of unrecognized tax benefits could significantly increase or decrease within the next twelve months .
items that may cause changes to unrecognized tax benefits include the timing of interest deductions , the deductibility of acquisition costs , the consideration of filing requirements in various states , the allocation of income and expense between tax jurisdictions and the effects of terminating an election to have a foreign subsidiary join in filing a consolidated return .
these changes could result from the settlement of ongoing litigation , the completion of ongoing examinations , the expiration of the statute of limitations , or other unforeseen circumstances .
at this time , an estimate of the range of the reasonably possible change cannot be .

Question: what portion of the balance of unrecognized tax benefits as of december 2017 will impact the effective tax rate?
Answer: 37.7%
Calculation: divide(134, 355)