RSUs issued under the 2007 Stock Incentive Plan and the 1998 Stock Option Plan provide for the issuance of a share of the Company’s common stock at no cost to the holder.
They are generally subject to performance criteria determined by the Compensation Committee, as well as time-based vesting such that, in general, 50% of the RSUs granted vest (subject to satisfaction of the performance criteria) on each of the fourth and fifth anniversaries of the grant date.
Certain of the Company’s executive officers and other employees have been awarded RSUs with different vesting criteria.
Prior to vesting, RSUs do not have dividend equivalent rights, do not have voting rights and the shares underlying the RSUs are not considered issued and outstanding.
Restricted shares issued under the Tektronix 2005 Stock Incentive Plan were granted subject to certain time-based vesting restrictions such that the restricted share awards are fully vested after a period of five years.
Holders of restricted shares have the right to vote such shares and receive dividends.
The restricted shares are considered issued and outstanding at the date the award is granted.
The options, RSUs and restricted shares generally vest only if the employee is employed by the Company on the vesting date or in other limited circumstances and unvested options and RSUs are forfeited upon retirement before age 65 unless the Compensation Committee of the Board of Directors determines otherwise.
To cover the exercise of options and vesting of RSUs, the Company generally issues new shares from its authorized but unissued share pool.
At December 31, 2008, approximately 7 million shares of the Company’s common stock were reserved for issuance under the 2007 Stock Incentive Plan.
The Company accounts for share-based compensation in accordance with Statement of Financial Accounting Standards (SFAS) No.123 (revised 2004), Share-Based Payment, which requires the Company to measure the cost of employee services received in exchange for all equity awards granted, including stock options, RSUs and restricted shares, based on the fair value of the award as of the grant date.
The estimated fair value of the options granted during 2008 and prior years was calculated using a Black-Scholes Merton option pricing model (Black-Scholes).
The following summarizes the assumptions used in the Black-Scholes models for the years ended December 31, 2008, 2007 and 2006:
## Table 0 ##
The Black-Scholes model incorporates assumptions to value stock-based awards.
The risk-free rate of interest for periods within the contractual life of the option is based on a zero-coupon U. S.  government instrument over the expected term of the equity instrument.
Expected volatility is based on implied volatility from traded options on the Company’s stock and historical volatility of the Company’s stock.
To estimate the option exercise timing to be used in the valuation model, in addition to considering the vesting period and contractual term of the option, the Company analyzes and considers actual historical exercise data for previously granted options.
At the time of grant, the Company estimates the number of options that it expects will be forfeited based on the Company’s historical experience.
Separate groups of employees that have similar behavior with regard to holding options for longer periods and different forfeiture rates are considered separately for valuation and attribution purposes.
In January 2006, the Company commenced an all cash tender offer for all of the outstanding ordinary shares of First Technology plc, a U. K.  - based public company.
In connection with the offer, the Company acquired an aggregate of 19.5% of First Technology’s issued share capital for $84 million.
A competing bidder subsequently made an offer that surpassed the Company’s bid, and as a result the Company allowed its offer for First Technology to lapse.
The Company tendered its shares into the other bidder’s offer and on April 7, 2006 received proceeds of $98 million from the sale of these shares, in addition to a $3 million break-up fee paid by First Technology to the Company.
The Company recorded a pre-tax gain of approximately $14 million ($8.9 million after-tax, or $0.03 per diluted share) upon the sale of these securities including the related break-up fee, net of related transaction costs during the year ended December 31, 2006, which is included in “other (income) expense, net” in the accompanying Statement of Earnings.
The following table summarizes the estimated fair values of the assets acquired and liabilities assumed at the date of acquisition for all acquisitions consummated during 2008, 2007, and 2006 and the individually significant acquisitions in 2007 and 2006 discussed above ($ in thousands):
## Table 1 ##
Significant 2007 Acquisitions
## Table 2 ##
Included in deferred income taxes as of December 31, 2008 are tax benefits for U. S.  and non-U.
S.  net operating loss carryforwards totaling $89 million (net of applicable valuation allowances of $136 million).
Certain of the losses can be carried forward indefinitely and others can be carried forward to various dates through 2028.
In addition, the Company had general business and foreign tax credit carryforwards of $65 million at December 31, 2008 and also has recorded a deferred tax asset for foreign credits of $49 million related to the indirect impact of certain unrecognized tax benefits (see below).
The Company adopted the provisions of FASB Interpretation No.48, Accounting for Uncertainty in Income Taxes, on January 1, 2007.
As a result of the implementation of Interpretation No.48, the Company recognized a decrease in the liability for unrecognized tax benefits of $63 million, which was accounted for as an increase to the January 1, 2007 balance of retained earnings.
As of December 31, 2007, gross unrecognized tax benefits totaled $475 million ($408 million, net of offsetting indirect tax benefits and including $81 million associated with potential interest and penalties).
As of December 31, 2008, gross unrecognized tax benefits totaled $447 million ($426 million, net of offsetting indirect tax benefits and including $89 million associated with potential interest and penalties).
Upon adoption of SFAS No 141R effective January 1, 2009 (see Note 19) all unrecognized tax benefits at December 31, 2008 (including accrued interest and penalties) will impact the effective rate if ultimately recognized.
Unrecognized tax benefits and associated accrued interest and penalties are included in “Taxes, income and other” in accrued expenses as detailed in Note 7.
The Company recognizes potential accrued interest and penalties associated with unrecognized tax positions within its global operations in income tax expense.
The Company recognized approximately $19 million and $24 million in potential interest and penalties associated with uncertain tax positions during 2008 and 2007, respectively.
To the extent interest and penalties are not assessed with respect to uncertain tax positions, amounts accrued will be reduced and reflected as a reduction of the overall income tax provision.
A reconciliation of the beginning and ending amount of unrecognized tax benefits, excluding amounts accrued for potential interest and penalties, is as follows ($ in thousands):
## Table 3 ##
The Company and its subsidiaries are routinely examined by various taxing authorities.
The Internal Revenue Service (“IRS”) has initiated examinations of certain of the Company’s Federal income tax returns for the years 2006 and 2007.
In addition, the Company has subsidiaries in Germany, Canada, France, and various other states, provinces and countries that are currently under audit for years ranging from 2001 through 2007.
To date, there have been no adjustments associated with in-process or recently settled audits that would have a material impact on the Company’s financial position or results of operations.
The Company files numerous consolidated and separate income tax returns in the United States Federal jurisdiction and in many state and foreign jurisdictions.
With few exceptions, the Company is no longer subject to U. S.  Federal income tax examinations for years before 2004 and is no longer subject to state, local and foreign income tax examinations by tax authorities for years before 2001.
Notes to the Consolidated Financial Statements 25.
Separation and Merger Transaction On January, 28, 2013, the Company completed the previously announced separation of its commodity chemicals business and merger of its wholly-owned subsidiary, Eagle Spinco Inc. , with a subsidiary of Georgia Gulf Corporation in a tax efficient Reverse Morris Trust transaction (the “Transaction”).
Pursuant to the merger, Eagle Spinco, the entity holding PPG's former commodity chemicals business, is now a wholly-owned subsidiary of Georgia Gulf.
The closing of the merger followed the expiration of the related exchange offer and the satisfaction of certain other conditions.
The combined company formed by uniting Georgia Gulf with PPG's former commodity chemicals business is named Axiall Corporation (“Axiall”).
PPG holds no ownership interest in Axiall.
PPG received the necessary ruling from the Internal Revenue Service and as a result this Transaction was generally tax free to PPG and its shareholders.
Under the terms of the exchange offer, 35,249,104 shares of Eagle Spinco common stock were available for distribution in exchange for shares of PPG common stock accepted in the offer.
Following the merger, each share of Eagle Spinco common stock automatically converted into the right to receive one share of Axiall Corporation common stock.
Accordingly, PPG shareholders who tendered their shares of PPG common stock as part of this offer received 3.2562 shares of Axiall common stock for each share of PPG common stock accepted for exchange.
PPG was able to accept the maximum of 10,825,227 shares of PPG common stock for exchange in the offer, and thereby, reduced its outstanding shares by approximately 7%.
Under the terms of the Transaction, PPG received $900 million of cash and 35.2 million shares of Axiall common stock (market value of $1.8 billion on January 25, 2013) which was distributed to PPG shareholders by the exchange offer as described above.
The cash consideration is subject to customary post-closing adjustment, including a working capital adjustment.
In the Transaction, PPG transferred environmental remediation liabilities, defined benefit pension plan assets and liabilities and other post-employment benefit liabilities related to the commodity chemicals business to Axiall.
PPG will report a gain on the Transaction reflecting the excess of the sum of the cash proceeds received and the cost (closing stock price on January 25, 2013) of the PPG shares tendered and accepted in the exchange for the 35.2 million shares of Axiall common stock over the net book value of the net assets of PPG's former commodity chemicals business.
The Transaction will also result in a net partial settlement loss associated with the spin out and termination of defined benefit pension liabilities and the transfer of other post-retirement benefit liabilities under the terms of the Transaction.
During 2012, the Company incurred $21 million of pretax expense, primarily for professional services, related to the Transaction.
Additional Transaction-related expenses will be incurred in 2013.
PPG will report the results of its commodity chemicals business for January 2013 and a net gain on the Transaction as results from discontinued operations when it reports its results for the quarter ending March 31, 2013.
In the PPG results for prior periods, presented for comparative purposes beginning with the first quarter 2013, the results of its former commodity chemicals business will be reclassified from continuing operations and presented as the results from discontinued operations.
The net sales and income before income taxes of the commodity chemicals business that will be reclassified and reported as discontinued operations are presented in the table below for the years ended December 31, 2012, 2011 and 2010:

<table><tr><td></td><td colspan="3"> Years Ended December 31,</td></tr><tr><td></td><td>2008</td><td>2007</td><td> 2006</td></tr><tr><td>Risk-free interest rate</td><td>2.75 - 3.80%</td><td>3.68 - 4.77%</td><td>4.39 - 5.1%</td></tr><tr><td>Weighted average volatility</td><td>27%</td><td>22%</td><td>22%</td></tr><tr><td>Dividend yield</td><td>0.2%</td><td>0.1 - 0.2%</td><td>0.1%</td></tr><tr><td>Expected years until exercise</td><td>6 - 9.5</td><td>7.5 - 9.5</td><td>7.5 - 9.5</td></tr></table>
<table><tr><td> Overall</td><td>2008</td><td>2007</td><td>2006</td></tr><tr><td>Accounts receivable</td><td>$43,788</td><td>$200,199</td><td>$143,441</td></tr><tr><td>Inventory</td><td>56,370</td><td>207,336</td><td>136,855</td></tr><tr><td>Property, plant and equipment</td><td>30,139</td><td>202,203</td><td>116,388</td></tr><tr><td>Goodwill</td><td>264,557</td><td>2,455,473</td><td>2,009,826</td></tr><tr><td>Other intangible assets, primarily customer relationships, trade names and patents</td><td>88,668</td><td>884,263</td><td>865,449</td></tr><tr><td>In-process research and development</td><td>—</td><td>60,400</td><td>6,500</td></tr><tr><td>Refundable escrowed purchase price</td><td>—</td><td>48,504</td><td>—</td></tr><tr><td>Accounts payable</td><td>-16,112</td><td>-57,617</td><td>-50,057</td></tr><tr><td>Other assets and liabilities, net</td><td>-35,921</td><td>-420,418</td><td>-389,200</td></tr><tr><td>Assumed debt</td><td>-8,281</td><td>-3,781</td><td>-183,167</td></tr><tr><td>Net cash consideration</td><td>$423,208</td><td>$3,576,562</td><td>$2,656,035</td></tr></table>
<table><tr><td> Significant 2007 Acquisitions</td><td>Tektronix</td><td>ChemTreat</td><td>All Others</td><td>Total</td></tr><tr><td>Accounts receivable</td><td>$149,315</td><td>$33,982</td><td>$16,902</td><td>$200,199</td></tr><tr><td>Inventory</td><td>181,753</td><td>6,541</td><td>19,042</td><td>207,336</td></tr><tr><td>Property, plant and equipment</td><td>185,567</td><td>10,655</td><td>5,981</td><td>202,203</td></tr><tr><td>Goodwill</td><td>1,874,578</td><td>330,847</td><td>250,048</td><td>2,455,473</td></tr><tr><td>Other intangible assets, primarily customer relationships, trade names and patents</td><td>720,000</td><td>72,000</td><td>92,263</td><td>884,263</td></tr><tr><td>In-process research and development</td><td>60,400</td><td>—</td><td>—</td><td>60,400</td></tr><tr><td>Refundable escrowed purchase price</td><td>48,504</td><td>—</td><td>—</td><td>48,504</td></tr><tr><td>Accounts payable</td><td>-35,919</td><td>-11,468</td><td>-10,230</td><td>-57,617</td></tr><tr><td>Other assets and liabilities, net</td><td>-401,308</td><td>-17,891</td><td>-1,219</td><td>-420,418</td></tr><tr><td>Assumed debt</td><td>—</td><td>—</td><td>-3,781</td><td>-3,781</td></tr><tr><td>Net cash consideration</td><td>$2,782,890</td><td>$424,666</td><td>$369,006</td><td>$3,576,562</td></tr></table>
<table><tr><td></td><td>2008</td><td>2007</td></tr><tr><td> Unrecognized tax benefits, beginning of year</td><td>$475,107</td><td>$331,701</td></tr><tr><td>Additions based on tax positions related to the current year</td><td>48,588</td><td>35,871</td></tr><tr><td>Additions for tax positions of prior years</td><td>25,095</td><td>63,315</td></tr><tr><td>Reductions for tax position of prior years</td><td>-47,567</td><td>-37,075</td></tr><tr><td>Acquisitions</td><td>—</td><td>62,122</td></tr><tr><td>Lapse of statute of limitations</td><td>-2,772</td><td>-673</td></tr><tr><td>Settlements</td><td>-26,384</td><td>-2,043</td></tr><tr><td>Effect of foreign currency translation</td><td>-25,175</td><td>21,889</td></tr><tr><td> Unrecognized tax benefits, end of year</td><td>$446,892</td><td>$475,107</td></tr></table>

Question: What is the average amount of Unrecognized tax benefits, end of year of 2008, and Refundable escrowed purchase price of Tektronix ?
Answer: 247698