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Income Taxes
6 Months Ended
Jun. 30, 2012
Income Taxes

NOTE 11—Income Taxes

At June 30, 2012 and December 31, 2011, the Company’s net deferred tax asset balance was $1.0 billion and $1.3 billion, respectively. The decrease in the net deferred tax asset was due to the reduction in the allowance for loan losses and an increase in unrealized gains on securities available for sale.

During 2010, the Internal Revenue Service (“IRS”) completed the field examination for the tax years 2007, 2008 and 2009. Included within the Revenue Agent’s Reports was a proposed adjustment to the timing of deductions related to certain expenses. In 2011, the Company filed a protest with the IRS Appeals Division. During the quarter ended June 30, 2012, the Company reached an agreement with the IRS that effectively settled this examination. At this time, the Company has no expectation that the settlement related to any of the protested positions will be reexamined. All years subsequent to 2009 are open to examination.

The Company has established a valuation allowance against certain state net operating loss and credit carryforwards in the amount of $59 million and $32 million at June 30, 2012, and December 31, 2011, respectively. The valuation allowance increased $27 million during the three and six month periods ended June 30, 2012 due to uncertainties in the timing of certain tax planning strategies that affected the ability to utilize state net operating losses before the prescribed expiration dates.

At June 30, 2012 and December 31, 2011, the balance of the Company’s unrecognized tax benefits (“UTBs”) was $56 million and $39 million, respectively. The increase is principally related to tax positions taken in the current year related to a realignment within the corporate organization structure. As of June 30, 2012 and December 31, 2011, the balance of the UTBs that would reduce the effective tax rate, if recognized, was $40 million and $25 million, respectively.