deferred tax assets and liabilities are recorded in the accompanying consolidated balance sheet under the captions deferred income tax assets , deferred charges and other assets , other accrued liabilities and deferred income taxes .
the decrease in 2009 in deferred tax assets principally relates to the tax impact of changes in recorded qualified pension liabilities , minimum tax credit utilization and an increase in the valuation allowance .
the decrease in deferred income tax liabilities principally relates to less tax depreciation taken on the company 2019s assets purchased in 2009 .
the valuation allowance for deferred tax assets as of december 31 , 2008 was $ 72 million .
the net change in the total valuation allowance for the year ended december 31 , 2009 , was an increase of $ 274 million .
the increase of $ 274 million consists primarily of : ( 1 ) $ 211 million related to the company 2019s french operations , including a valuation allowance of $ 55 million against net deferred tax assets from current year operations and $ 156 million recorded in the second quarter of 2009 for the establishment of a valuation allowance against previously recorded deferred tax assets , ( 2 ) $ 10 million for net deferred tax assets arising from the company 2019s united king- dom current year operations , and ( 3 ) $ 47 million related to a reduction of previously recorded u.s .
state deferred tax assets , including $ 15 million recorded in the fourth quarter of 2009 for louisiana recycling credits .
the effect on the company 2019s effec- tive tax rate of the aforementioned $ 211 million and $ 10 million is included in the line item 201ctax rate and permanent differences on non-u.s .
earnings . 201d international paper adopted the provisions of new guidance under asc 740 , 201cincome taxes , 201d on jan- uary 1 , 2007 related to uncertain tax positions .
as a result of the implementation of this new guidance , the company recorded a charge to the beginning balance of retained earnings of $ 94 million , which was accounted for as a reduction to the january 1 , 2007 balance of retained earnings .
a reconciliation of the beginning and ending amount of unrecognized tax benefits for the year ending december 31 , 2009 and 2008 is as follows : in millions 2009 2008 2007 .

<i>In millions</i>
2009
2008
2007
Balance at January 1
$(435)
$(794)
(919)
Additions based on tax positions related to current year
(28)
(14)
(12)
Additions for tax positions of prior years
(82)
(66)
(30)
Reductions for tax positions of prior years
72
67
74
Settlements
174
352
112
Expiration of statutes of limitations
2
3
5
Currency translation adjustment
(11)
17
(24)
Balance at December 31
$(308)
$(435)
$(794)

included in the balance at december 31 , 2009 and 2008 are $ 56 million and $ 9 million , respectively , for tax positions for which the ultimate benefits are highly certain , but for which there is uncertainty about the timing of such benefits .
however , except for the possible effect of any penalties , any dis- allowance that would change the timing of these benefits would not affect the annual effective tax rate , but would accelerate the payment of cash to the taxing authority to an earlier period .
the company accrues interest on unrecognized tax benefits as a component of interest expense .
penal- ties , if incurred , are recognized as a component of income tax expense .
the company had approx- imately $ 95 million and $ 74 million accrued for the payment of estimated interest and penalties asso- ciated with unrecognized tax benefits at december 31 , 2009 and 2008 , respectively .
the major jurisdictions where the company files income tax returns are the united states , brazil , france , poland and russia .
generally , tax years 2002 through 2009 remain open and subject to examina- tion by the relevant tax authorities .
the company is typically engaged in various tax examinations at any given time , both in the united states and overseas .
currently , the company is engaged in discussions with the u.s .
internal revenue service regarding the examination of tax years 2006 and 2007 .
as a result of these discussions , other pending tax audit settle- ments , and the expiration of statutes of limitation , the company currently estimates that the amount of unrecognized tax benefits could be reduced by up to $ 125 million during the next twelve months .
during 2009 , unrecognized tax benefits decreased by $ 127 million .
while the company believes that it is adequately accrued for possible audit adjustments , the final resolution of these examinations cannot be determined at this time and could result in final settlements that differ from current estimates .
the company 2019s 2009 income tax provision of $ 469 million included $ 279 million related to special items and other charges , consisting of a $ 534 million tax benefit related to restructuring and other charges , a $ 650 million tax expense for the alternative fuel mixture credit , and $ 163 million of tax-related adjustments including a $ 156 million tax expense to establish a valuation allowance for net operating loss carryforwards in france , a $ 26 million tax benefit for the effective settlement of federal tax audits , a $ 15 million tax expense to establish a valuation allow- ance for louisiana recycling credits , and $ 18 million of other income tax adjustments .
excluding the impact of special items , the tax provision was .

Question: Analyse this data from a financial earnings document. based on the review of the unrecognized tax benefits what was the average settlement amount from 2007 to 2009 in millions
Choices:
961.5
106.3
320.5
0
317.5
Correct choice index: 2