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Income Taxes
3 Months Ended
Mar. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
The following table presents the calculation of the Company's effective income tax rate (dollars in millions, except effective income tax rate):
 
For the Three Months Ended March 31,
 
2020
 
2019
(Loss) income before income taxes
$
(78
)
 
$
930

Income tax (benefit) expense
$
(17
)
 
$
204

Effective income tax rate
22.0
%
 
21.9
%
 
 
 
 

The income tax expense decreased $221 million for the three months ended March 31, 2020 as compared to the same period in 2019 due to a pretax loss for the current period. The effective tax rate was relatively flat for the three months ended March 31, 2020 as compared to the same period in 2019. The effective rate for three months ended March 31, 2019 was favorably impacted by the resolution of certain tax matters.
The Company is subject to examination by the Internal Revenue Service ("IRS") and tax authorities in various state, local and foreign tax jurisdictions. The Company regularly assesses the likelihood of additional assessments or settlements in each of the taxing jurisdictions resulting from these and subsequent years' examinations. The years 2011-2015 are currently under review by the IRS Office of Appeals. At this time, the potential change in unrecognized tax benefits is not expected to be significant over the next 12 months. The Company believes that its reserves are sufficient to cover any tax, penalties and interest that would result from such examinations.