Coca-Cola said Friday it will fight a $3.3 billion tax bill it has received from the Internal Revenue Service.

The federal agency says a five-year audit of the Atlanta-based beverage giant found it paid insufficient income tax between 2007 and 2009, Coke said Friday in an SEC filing.

The IRS said Coke’s taxable income should be increased by an amount equal to the $3.3 billion liability, plus interest, Coke said in the filing.

However, no penalties are being assessed.

The contested funds relate to the overseas sale, marketing and manufacturing of the company’s products, such as Coke and Diet Coke.

Coke said it thinks the IRS assessment is wrong and that it “intends to vigorously defend its position and is confident in its ability to prevail on the merits.”