the aggregate changes in the balance of gross unrecognized tax benefits , which excludes interest and penalties , for 2012 , 2011 , and 2010 , is as follows ( in millions ) : .
what was the aggregate change in the ending balance of gross unrecognized tax benefits , which excludes interest and penalties between 2012 and 2011?
the company includes interest and penalties related to unrecognized tax benefits within the provision for income taxes . as of september 29 , 2012 and september 24 , 2011 , the total amount of gross interest and penalties accrued was $ 401 million and $ 261 million , respectively , which is classified as non-current liabilities in the consolidated balance sheets . in connection with tax matters , the company recognized interest expense in 2012 and 2011 of $ 140 million and $ 14 million , respectively , and in 2010 the company recognized an interest benefit of $ 43 million . the company is subject to taxation and files income tax returns in the u.s . federal jurisdiction and in many state and foreign jurisdictions . for u.s . federal income tax purposes , all years prior to 2004 are closed . the internal revenue service ( the 201cirs 201d ) has completed its field audit of the company 2019s federal income tax returns for the years 2004 through 2006 and proposed certain adjustments . the company has contested certain of these adjustments through the irs appeals office . the irs is currently examining the years 2007 through 2009 . in addition , the company is also subject to audits by state , local and foreign tax authorities . in major states and major foreign jurisdictions , the years subsequent to 1989 and 2002 , respectively , generally remain open and could be subject to examination by the taxing authorities . management believes that an adequate provision has been made for any adjustments that may result from tax examinations . however , the outcome of tax audits cannot be predicted with certainty . if any issues addressed in the company 2019s tax audits are resolved in a manner not consistent with management 2019s expectations , the company could be required to adjust its provision for income tax in the period such resolution occurs . although timing of the resolution and/or closure of audits is not certain , the company believes it is reasonably possible that tax audit resolutions could reduce its unrecognized tax benefits by between $ 120 million and $ 170 million in the next 12 months . note 6 2013 shareholders 2019 equity and share-based compensation preferred stock the company has five million shares of authorized preferred stock , none of which is issued or outstanding . under the terms of the company 2019s restated articles of incorporation , the board of directors is authorized to determine or alter the rights , preferences , privileges and restrictions of the company 2019s authorized but unissued shares of preferred stock . dividend and stock repurchase program in 2012 , the board of directors of the company approved a dividend policy pursuant to which it plans to make , subject to subsequent declaration , quarterly dividends of $ 2.65 per share . on july 24 , 2012 , the board of directors declared a dividend of $ 2.65 per share to shareholders of record as of the close of business on august 13 , 2012 . the company paid $ 2.5 billion in conjunction with this dividend on august 16 , 2012 . no dividends were declared in the first three quarters of 2012 or in 2011 and 2010. .