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 percentage change in the gross unrecognized tax benefits between 2010 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. .