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Income Taxes
6 Months Ended
Jun. 30, 2014
Income Tax Disclosure [Abstract]  
Income Taxes
(7) Income Taxes

On May 19, 2012, CVR became a member of the consolidated federal tax group of AEPC, a wholly-owned subsidiary of IEP, and subsequently entered into a tax allocation agreement with AEPC (the “Tax Allocation Agreement”). The Tax Allocation Agreement provides that AEPC will pay all consolidated federal income taxes on behalf of the consolidated tax group. CVR is required to make payments to AEPC in an amount equal to the tax liability, if any, that it would have paid if it were to file as a consolidated group separate and apart from AEPC. As of June 30, 2014, the Company has recorded a liability of $28.0 million for federal income taxes due to AEPC under the Tax Allocation Agreement. During each of the three and six month periods ended June 30, 2014 and 2013, the Company paid $98.1 million and $139.0 million, respectively, to AEPC under the Tax Allocation Agreement.

The Company recognizes liabilities, interest and penalties for potential tax issues based on its estimate of whether, and the extent to which, additional taxes may be due as determined under ASC Topic 740—Income Taxes. As of June 30, 2014, the Company had unrecognized tax benefits of approximately $52.6 million, of which $23.5 million, if recognized, would impact the Company’s effective tax rate. Approximately $13.9 million of unrecognized tax benefits associated with state tax credits were netted with deferred tax asset carryforwards. The remaining unrecognized tax benefits are included in other long-term liabilities in the Condensed Consolidated Balance Sheets. There are no unrecognized tax benefits expected to be settled within the next twelve months in income taxes payable. The Company has accrued interest of $4.6 million related to uncertain tax positions. The Company’s accounting policy with respect to interest and penalties related to tax uncertainties is to classify these amounts as income taxes.

CVR and its subsidiaries file U.S. federal and various state income and franchise tax returns. At June 30, 2014, the Company’s tax filings are generally open to examination in the United States for the tax years ended December 31, 2010 through December 31, 2013 and in various individual states for the tax years ended December 31, 2009 through December 31, 2013.

The Company’s effective tax rate for the three and six months ended June 30, 2014 was 23.9% and 24.3%, respectively, as compared to the Company’s combined federal and state expected statutory tax rate of 39.6%. The Company’s effective tax rate for the three and six months ended June 30, 2014 is lower than the statutory rate primarily due to the reduction of income subject to tax associated with the noncontrolling ownership interests of CVR Refining’s and CVR Partners’ earnings, as well as benefits for domestic production activities and state income tax credits. The Company’s effective tax rate for the three and six months ended June 30, 2013 was 26.8% and 28.5% as compared to the Company’s combined federal and state expected statutory tax rate of 39.2%. The Company’s effective tax rate for the three and six months ended June 30, 2013 was lower than the statutory rate primarily due to the reduction of income subject to tax associated with the noncontrolling ownership interests of CVR Refining's and CVR Partners’ earnings, as well as benefits for domestic production activities and state income tax credits.