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 ( 201cirs 201d ) .
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 201cpenalty 201d tax pursuant to section 857 ( b ) ( 7 ) of the code and disallow the capital loss deduction .
the notice of proposed adjustment indicates the irs 2019 intention to impose the 100 percent 201cpenalty 201d 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 2019 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 2019 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 2019s 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 2019s 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 2019s 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 2019s 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 ) : .

201 4
2013
Balance, beginning of year
$4,590
$16,890
Increases for tax positions related to current year
59
15
Reduction due to adoption of ASU 2013-11(a)
-
(12,315)
Balance, end of year
$4,649
$4,590

( a ) this amount was reclassified against the related deferred tax asset relating to the company 2019s early adoption of asu 2013-11 as discussed above. .

Question: Analyse this data from a financial earnings document. what is the proportion of dollars at the beginning of both combined years to dollars at end of both combined years?
Choices:
21480
2.32493
232.49269
3.65624
4.61638
Correct choice index: 1