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The following table sets forth changes in our total gross unrec- ognized tax benefit liabilities, excluding accrued interest, for fiscal 2010. Approximately $206.4 million of this total represents the amount that, if recognized, would affect our effective income tax rate in future periods. This amount differs from the gross unrec- ognized tax benefits presented in the table because certain of the liabilities below would impact deferred taxes if recognized or are the result of stock compensation items impacting additional paid- in capital. We also would record a decrease in U.S. federal income taxes upon recognition of the state tax benefits included therein. 

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As of May 30, 2010, we have classified $299.0 million of the unrecognized tax benefits as a current liability as we expect to pay these amounts within the next 12 months, including a portion of our potential liability for the matter resolved by the U.S. Court of Appeals, as discussed above. While fiscal years 2007 and 2008 are currently under examination by the Internal Revenue Service (IRS), we are not able to reasonably estimate the timing of future cash flows beyond 12 months due to uncertainties in the timing of this and other tax audit outcomes. The remaining amount of our unrecognized tax liability was classified in other liabilities. 

We report accrued interest and penalties related to unrecog- nized tax benefits in income tax expense. For fiscal 2010, we recognized a net $16.2 million of tax-related net interest and penalties, and had $174.8 million of accrued interest and penalties as of May 30, 2010. 

## NOTE 15. LEASES AND OTHER COMMITMENTS 

An analysis of rent expense by type of property for operating leases follows: 

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Some operating leases require payment of property taxes, insurance, and maintenance costs in addition to the rent pay- ments. Contingent and escalation rent in excess of minimum rent payments and sublease income netted in rent expense were insignificant. 

Noncancelable future lease commitments are: 

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These future lease commitments will be partially offset by estimated future sublease receipts of $16 million. Depreciation on capital leases is recorded as depreciation expense in our results of operations. 

As of May 30, 2010, we have issued guarantees and comfort letters of $537.5 million for the debt and other obligations of con- solidated subsidiaries, and guarantees and comfort letters of $301.6 million for the debt and other obligations of nonconsolidated affiliates, mainly CPW. In addition, off-balance sheet arrangements are generally limited to the future payments under noncancelable operating leases, which totaled $315.3 million as of May 30, 2010. 

