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Income Taxes
6 Months Ended
Jun. 30, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
For the three-month and six-month periods ended June 30, 2013, there were no material changes to the total amount of unrecognized tax benefits. We accrued interest of $86 thousand and $80 thousand during the three-month periods ended June 30, 2013 and June 30, 2012, respectively, and $165 thousand and $151 thousand during the six-month periods ended June 30, 2013 and June 30, 2012, respectively. Our total gross liability for unrecognized tax benefits at June 30, 2013 is $12.1 million. If recognized, $7.7 million of unrecognized tax benefits would impact our effective tax rate. Interest of $3.8 million has been reflected as a component of the total liability. We expect no other significant increases or decreases for uncertain tax positions during the next twelve months.
We file U.S. federal income tax returns, as well as income tax returns in various states and several foreign jurisdictions. The years 2009 through 2012 are open for examination by the Internal Revenue Service (“IRS”), and various years are open for examination by state and foreign tax authorities. State and foreign jurisdictional statutes of limitations generally range from three to four years.
In May 2010, the IRS began an audit of our 2007 and 2008 federal income tax returns. During the second quarter of 2012, we received a notice of deficiency including proposed penalties related to our like-kind exchange program for tractors and trailers. The proposed tax deficiency relates to timing differences for recognition of gains on sales of equipment. The IRS position would subject us to interest charges, which we estimated as of March 31, 2013 to be approximately $2.1 million after considering the tax deductibility of the interest payments, plus proposed penalties. In July 2012, we filed a petition in the United States Tax Court to contest the notice of deficiency. The IRS responded to our petition in September 2012. Prior to holding a scheduled appeals conference in June 2013, the IRS appeals officer decided to no longer contest this issue based on the merits of our position.  In July 2013, we entered into a stipulation with the IRS that there are no deficiencies in federal income tax and no penalties due for the tax years 2007 and 2008. The IRS decision has no impact on our financial condition, results of operations or income tax rate because we had not previously accrued a liability for any proposed interest or penalties related to this issue.