the following table summarizes the changes in the total amounts of unrealized tax benefits for fiscal 2009 through fiscal 2011. .
what is the net change in unrealized tax benefits during 2010?
fiscal years 2004 and 2005 irs examination during the fourth quarter of fiscal 2007 , the internal revenue service ( irs ) completed its field examination of the company 2019s fiscal years 2004 and 2005 . on january 2 , 2008 , the irs issued its report for fiscal 2004 and 2005 , which included four proposed adjustments related to these two fiscal years that the company protested to the irs appeals office . two of the unresolved matters were one-time issues that pertain to section 965 of the internal revenue code related to the beneficial tax treatment of dividends paid from foreign owned companies under the american jobs creation act . the other matters pertained to the computation of the research and development ( r&d ) tax credit and certain profits earned from manufacturing activities carried on outside the united states . the company recorded a tax liability for a portion of the proposed r&d tax credit adjustment . these four items had an additional potential tax liability of $ 46 million . the company concluded , based on discussions with its tax advisors , that these items were not likely to result in any additional tax liability . therefore , the company did not record a tax liability for these items . during the second quarter of fiscal 2011 , the company reached settlement with the irs appeals office on three of the four items under protest . the remaining unresolved matter is a one-time issue pertaining to section 965 of the internal revenue code related to the beneficial tax treatment of dividends from foreign owned companies under the american jobs creation act . the company will file a petition with the tax court with respect to this open matter . the potential liability for this adjustment is $ 36.5 million . the company has concluded , based on discussions with its tax advisors , that this item is not likely to result in any additional tax liability . therefore , the company has not recorded any additional tax liability for this issue . fiscal years 2006 and 2007 irs examination during the third quarter of fiscal 2009 , the irs completed its field examination of the company 2019s fiscal years 2006 and 2007 . the irs and the company agreed on the treatment of a number of issues that have been included in an issue resolutions agreement related to the 2006 and 2007 tax returns . however , no agreement was reached on the tax treatment of a number of issues for the fiscal 2006 and fiscal 2007 years , including the same r&d tax credit and foreign manufacturing issues mentioned above related to fiscal 2004 and 2005 , the pricing of intercompany sales ( transfer pricing ) and the deductibility of certain stock option compensation expenses . the company recorded taxes related to a portion of the proposed r&d tax credit adjustment . these four items had an additional potential total tax liability of $ 195 million . the company concluded , based on discussions with its tax advisors that these items were not likely to result in any additional tax liability . therefore , the company did not record any additional tax liability for these items and appealed these proposed adjustments through the normal processes for the resolution of differences between the irs and taxpayers . during the second quarter of fiscal 2011 , the company reached an agreement with the irs appeals office on three of the four protested items , two of which were the same issues settled relating to the 2004 and 2005 fiscal years . transfer pricing remained as the only item under protest with the irs appeals office related to the fiscal analog devices , inc . notes to consolidated financial statements 2014 ( continued ) .