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Income Taxes
3 Months Ended
Mar. 31, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
Our effective tax rate, exclusive of noncontrolling interests, for the three months ended March 31, 2013 and 2012 was 31.9% and 36.0%, respectively. The effective tax rate for the three months ended March 31, 2013 was favorably affected by the resolution of our 2009-2010 tax years with the IRS appeals division and subsequent review by the Congressional Joint Committee on Taxation. The effective tax rate for the three months ended March 31, 2012 was favorably affected by a change in estimated non-deductible penalties relating to certain legal settlements and adjustments resulting from filing amended state returns related to the December 2011 settlement of Allied's 2000-2003 tax years.
We record interim income tax expense based upon our anticipated full year effective income tax rate.
Cash paid for income taxes was a net refund of $14.0 million and $43.8 million for the three months ended March 31, 2013 and 2012, respectively. The net refund for the three months ended March 31, 2013 was driven primarily by the resolution of our 2009-2010 tax years. The net refund for the three months ended March 31, 2012 was due to a quick federal refund received related to a law change for bonus tax depreciation.
We recognize interest and penalties as incurred within the provision for income taxes in the consolidated statements of income. As of March 31, 2013, we have accrued a liability for penalties of $0.6 million and a liability for interest (including interest on penalties) of $13.6 million related to our uncertain tax positions.
We believe that our recorded liabilities for uncertain tax positions are adequate. However, a significant assessment against us in excess of the liabilities recorded could have a material adverse effect on our consolidated financial position, results of operations or cash flows.
During the next twelve months, it is reasonably possible that the amount of unrecognized tax benefits will increase or decrease. Gross unrecognized benefits that we expect to settle in the next twelve months are in the range of zero to $10 million.
We have deferred tax assets related to state net operating loss carryforwards for which we provide valuation allowances, as needed, due to uncertainty surrounding the future utilization of these carryforwards. When determining the need for a valuation allowance, we consider all positive and negative evidence, including scheduled reversals of deferred tax liabilities, projected future taxable income, tax planning strategies and recent financial results. In the period management determines it is more likely than not our state net operating loss carryforwards will or will not be recognized, we adjust the valuation allowance as necessary.

During the three months ended March 31, 2013, we have not changed our judgment regarding the future realizability of state net operating losses on which we provide a valuation allowance; however, we continue to monitor all positive and negative evidence and this may lead the company to change its judgment in a subsequent period.