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Income Taxes, Unrecognized Tax Benefits (Tables)

9 Months Ended

Sep. 30, 2011

Income Taxes, Unrecognized Tax Benefits

Schedule of change in unrecognized tax benefits

At September 30, 2011


	(In millions)
Total unrecognized tax benefits, January 1, 2011	$	239.8
Increases in tax positions related to the current year		0.9
Increases in tax positions related to prior years		29.7
Reductions in tax positions related to prior years		(89.1	)

Total unrecognized tax benefits, September 30, 2011¹	$	181.3

1 BGE's portion of our total unrecognized tax benefits at September 30, 2011 was $12.0 million.

Schedule of interest and penalties recorded as tax expense relating to liabilities for unrecognized tax benefits

	Quarter Ended September 30,					Nine Months Ended September 30,

	2011			2010		2011		2010

	(In millions)
Interest and penalties recorded as tax (benefit) expense	$	(1.6	)	$	3.0	$	3.9	$	(4.3	)

- Definition

Tabular disclosure of tax positions taken in the tax returns filed or to be filed for which it is more likely than not that the tax position will not be sustained upon examination by taxing authorities (i.e., uncertain tax positions) and other types of income tax contingencies, including: (1) the policy on classification of interest and penalties; (2) a tabular reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period; the total amount(s) of: (3) unrecognized tax benefits that, if recognized, would affect the effective tax rate, and (4) interest and penalties recognized in each of the income statement and balance sheet; (5) for positions for which it is reasonably possible that the total amounts unrecognized will significantly change within 12 months of the reporting date the: (i) nature of the uncertainty, (ii) nature of the event that could occur that would cause the change, and (iii) an estimate of the range of the reasonably possible change or a statement that an estimate of the range cannot be made; and (6) a description of tax years that remain subject to examination by major tax jurisdictions.

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