82 | 2017 form 10-k a reconciliation of the beginning and ending amount of gross unrecognized tax benefits for uncertain tax positions , including positions impacting only the timing of tax benefits , follows . reconciliation of unrecognized tax benefits:1 years a0ended a0december a031 .

Row 1: ( millions of dollars ), years ended december 31 , 2017, years ended december 31 , 2016
Row 2: balance at january 1,, $ 1032, $ 968
Row 3: additions for tax positions related to current year, 270, 73
Row 4: additions for tax positions related to prior years, 20, 55
Row 5: reductions for tax positions related to prior years, -27 ( 27 ), -36 ( 36 )
Row 6: reductions for settlements2, -9 ( 9 ), -24 ( 24 )
Row 7: reductions for expiration of statute of limitations, 2014, -4 ( 4 )
Row 8: balance at december 31,, $ 1286, $ 1032
Row 9: amount that if recognized would impact the effective tax rate, $ 1209, $ 963

1 foreign currency impacts are included within each line as applicable . 2 includes cash payment or other reduction of assets to settle liability . we classify interest and penalties on income taxes as a component of the provision for income taxes . we recognized a net provision for interest and penalties of $ 38 million , $ 34 million and $ 20 million during the years ended december 31 , 2017 , 2016 and 2015 , respectively . the total amount of interest and penalties accrued was $ 157 million and $ 120 million as of december a031 , 2017 and 2016 , respectively . on january 31 , 2018 , we received a revenue agent 2019s report from the irs indicating the end of the field examination of our u.s . income tax returns for 2010 to 2012 . in the audits of 2007 to 2012 including the impact of a loss carryback to 2005 , the irs has proposed to tax in the united states profits earned from certain parts transactions by csarl , based on the irs examination team 2019s application of the 201csubstance-over-form 201d or 201cassignment-of-income 201d judicial doctrines . we are vigorously contesting the proposed increases to tax and penalties for these years of approximately $ 2.3 billion . we believe that the relevant transactions complied with applicable tax laws and did not violate judicial doctrines . we have filed u.s . income tax returns on this same basis for years after 2012 . based on the information currently available , we do not anticipate a significant increase or decrease to our unrecognized tax benefits for this matter within the next 12 months . we currently believe the ultimate disposition of this matter will not have a material adverse effect on our consolidated financial position , liquidity or results of operations . with the exception of a loss carryback to 2005 , tax years prior to 2007 are generally no longer subject to u.s . tax assessment . in our major non-u.s . jurisdictions including australia , brazil , china , germany , japan , mexico , switzerland , singapore and the u.k. , tax years are typically subject to examination for three to ten years . due to the uncertainty related to the timing and potential outcome of audits , we cannot estimate the range of reasonably possible change in unrecognized tax benefits in the next 12 months. .

Question: assuming the same rate of change as in 2017 , what would the 2018 total amount of interest and penalties accrued equal in millions?
Program: divide(157, 120), multiply(#0, 157)
Answer: 205.40833