How did the DOJ and KPMG come to the number of 456 million?  Although it may seem like an odd number, the source of this amount is specifically laid out in the agreement. (see here)

1. "a fine consisting of disgorgement of 128,000,000 of fees received by KPMG from the activities described in the Statement of Facts"

2. "restitution to the IRS of $228,000,000 for…."

3. "100,000,000 to settle the IRS’s promoter penalty examination of KPMG….."

(esp)