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INCOME TAXES
 9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
A reconciliation between the amount of reported income tax expense and the amount computed by multiplying income before income taxes by the statutory federal tax rate is presented below:
Three Months Ended
September 30,		Nine Months Ended
September 30,
2025202420252024
Tax expense at statutory federal rate of 21%$149 $194 $445 $965 
State income taxes, net of federal income tax benefit23 66 78 291 
Tax benefit attributable to noncontrolling interests(50)(44)(144)(128)
Nondeductible goodwill— 33 — 161 
Stock-based compensation tax benefit(1)(1)(6)(7)
Changes in valuation allowance6 2 — (176)
Other items6 (9)23 (5)
Income tax expense$133 $241 $396 $1,101 
The One Big Beautiful Bill Act (OBBBA) was enacted on July 4, 2025, resulting in significant changes to the U.S. federal tax code. We do not believe it will have a material impact on current year tax expense. Taxable income and current tax liability will be reduced due to the reinstatement of 100% bonus depreciation and changes to business interest deduction limitations. Under section 740 of the Accounting Standards Codification, the effects of the tax law changes are recognized in the period of enactment, which is the three months ending September 30, 2025.
Income before income taxes for the three months ended September 30, 2025 and 2024 was $712 million and $922 million, respectively, and $2.119 billion and $4.593 billion for the nine months ended September 30, 2025 and 2024, respectively. Our provision for income taxes during interim reporting periods is calculated by applying an estimate of the annual effective tax rate to “ordinary” income or loss (pre-tax income or loss excluding unusual or infrequently occurring discrete items) for the reporting period. In calculating “ordinary” income, non‑taxable income available to noncontrolling interests was deducted from pre-tax income. During the nine months ended September 30, 2025, we recorded an increase of $1 million related to state interest expense carryforwards and a $1 million decrease related to a change in the realizability of deferred tax assets. During the nine months ended September 30, 2024, we recorded an income tax benefit of $176 million to decrease the valuation allowance, including a decrease of $193 million for utilization of interest expense carryforwards primarily due to gains from sales of facilities, and an increase of $17 million related to state interest expense carryforwards.
There were no adjustments to our estimated liabilities for uncertain tax positions during the nine months ended September 30, 2025. The total amount of unrecognized tax benefits as of September 30, 2025 was $71 million, of which $69 million, if recognized, would affect our effective tax rate and income tax benefit.
Our practice is to recognize interest and penalties related to income tax matters in income tax expense in our condensed consolidated statements of operations. Approximately $3 million of interest and penalties related to accrued liabilities for uncertain tax positions are included for the nine months ended September 30, 2025. Total accrued interest and penalties on unrecognized tax benefits at September 30, 2025 were $10 million.