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Income Taxes | 12 Months Ended
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Sep. 26, 2020
Income Tax Disclosure [Abstract] |
Income Taxes | 9.Income Taxes For federal income tax purposes, as well as for state income tax purposes in the majority of the states in which the Partnership operates, the earnings attributable to the Partnership and the Operating Partnership are not subject to income tax at the partnership level. With the exception of those states that impose an entity-level income tax on partnerships, the taxable income or loss attributable to the Partnership and to the Operating Partnership, which may vary substantially from the income (loss) before income taxes reported by the Partnership in the consolidated statement of operations, are includable in the federal and state income tax returns of the Common Unitholders. The aggregate difference in the basis of the Partnership’s net assets for financial and tax reporting purposes cannot be readily determined as the Partnership does not have access to each Common Unitholder’s basis in the Partnership. As described in Note 1 “Partnership Organization and Formation”, the earnings of the Corporate Entities are subject to U.S. corporate level income tax. However, based upon past performance, the Corporate Entities are currently reporting an income tax provision composed primarily of minimum state income taxes. A full valuation allowance has been provided against the deferred tax assets (with the exception of certain NOLs, which is defined and explained below, that arose after the enactment of the Tax Cuts and Jobs Act (“2017 Act”)) based upon an analysis of all available evidence, both negative and positive at the balance sheet date, which, taken as a whole, indicates that it is more likely than not that sufficient future taxable income will not be available to utilize the assets. Management’s periodic reviews include, among other things, the nature and amount of the taxable income and expense items, the expected timing of when assets will be used or liabilities will be required to be reported and the reliability of historical profitability of businesses expected to provide future earnings. Furthermore, management considered tax-planning strategies it could use to increase the likelihood that the deferred tax assets will be realized. On December 22, 2017, the 2017 Act was signed into law, which enacted significant changes to U.S. tax and related laws. Some of the provisions of the 2017 Act that could affect the Partnership, the Operating Partnership and their subsidiaries include, but are not limited to, a reduction of the federal corporate income tax rate from 35% to 21%, limitations on the deductibility of net business interest expense, restrictions on the use of net operating loss carryforwards (“NOLs”) arising in taxable years beginning after December 31, 2017 and full expensing for certain qualified property. Certain of these changes have been suspended or modified by the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). In the case of a corporation, the 2017 Act made Alternative Minimum Tax (“AMT”) credit carryforwards fully refundable without regard to future taxable income. Accordingly, the Partnership concluded that the existing valuation allowance on the AMT credit carryforwards of the Corporate Entities should be released as part of accounting for tax reform. The reversal of the valuation allowance resulted in a $1,086 discrete deferred tax benefit being recorded during the first quarter of fiscal 2018. As of September 26, 2020, all of the AMT credit carryforwards have been refunded. In addition, also as a result of the 2017 Act, NOLs generated beginning in 2018 may be carried forward indefinitely. As a result, the Partnership reversed the valuation allowance on certain of these NOLs generated after the 2017 Act, which resulted in a $496 discrete deferred tax benefit recorded during the first quarter of fiscal 2020. The income tax provision of all the legal entities included in the Partnership’s consolidated statement of operations, which is composed primarily of state income taxes in the few states that impose taxes on partnerships and minimum state income taxes on the Corporate Entities, consists of the following:
|  | Year Ended |
|  | September 26, |  |  | September 28, |  |  | September 29, |
|  | 2020 |  |  | 2019 |  |  | 2018 |
Current |  |  |  |  |  |  |  |  |  |  |  |
Federal |  | $ | 4 |  |  | $ | 67 |  |  | $ | 7 |
State and local |  |  | 346 |  |  |  | 790 |  |  |  | 473 |
|  |  | 350 |  |  |  | 857 |  |  |  | 480 |
Deferred |  |  | (496 | ) |  |  | — |  |  |  | (1,086 | )
|  | $ | (146 | ) |  | $ | 857 |  |  | $ | (606 | )
The provision for income taxes differs from income taxes computed at the U.S. federal statutory rate as a result of the following:
|  | Year Ended |
|  | September 26, |  |  | September 28, |  |  | September 29, |
|  | 2020 |  |  | 2019 |  |  | 2018 |
Income tax provision at federal statutory tax rate |  | $ | 12,728 |  |  | $ | 14,593 |  |  | $ | 15,945 |
Impact of Partnership income not subject to federal income taxes |  |  | (13,045 | ) |  |  | (14,925 | ) |  |  | (15,939 | )
Permanent differences |  |  | 127 |  |  |  | 162 |  |  |  | 65 |
Change in valuation allowance |  |  | (298 | ) |  |  | 115 |  |  |  | (21,307 | )
State income taxes |  |  | 403 |  |  |  | 707 |  |  |  | 656 |
Remeasurement of net deferred tax assets (1) |  |  | — |  |  |  | — |  |  |  | 19,941 |
Other |  |  | (61 | ) |  |  | 205 |  |  |  | 33 |
Provision for income taxes - current and deferred |  | $ | (146 | ) |  | $ | 857 |  |  | $ | (606 | )
The components of net deferred taxes and the related valuation allowance using currently enacted tax rates are as follows:
|  | Year Ended |
|  | September 26, |  |  | September 28, |
|  | 2020 |  |  | 2019 |
Deferred tax assets: |  |  |  |  |  |  |  |
Net operating loss carryforwards |  | $ | 38,217 |  |  | $ | 38,914 |
Allowance for doubtful accounts |  |  | 156 |  |  |  | 170 |
Inventory |  |  | 250 |  |  |  | 231 |
Deferred revenue |  |  | 575 |  |  |  | 615 |
AMT credit carryforward |  |  | — |  |  |  | 513 |
Other accruals |  |  | 2,092 |  |  |  | 1,416 |
Total deferred tax assets |  |  | 41,290 |  |  |  | 41,859 |
Deferred tax liabilities: |  |  |  |  |  |  |  |
Intangible assets |  |  | 1,197 |  |  |  | 1,205 |
Property, plant and equipment |  |  | 1,899 |  |  |  | 2,145 |
Total deferred tax liabilities |  |  | 3,096 |  |  |  | 3,350 |
Net deferred tax assets |  |  | 38,194 |  |  |  | 38,509 |
Valuation allowance |  |  | (37,698 | ) |  |  | (37,996 | )
Net deferred tax assets |  | $ | 496 |  |  | $ | 513 |

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 21 -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32857-109319 Reference 2: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section S99 -Paragraph 2 -Subparagraph (SAB Topic 11.C) -URI http://asc.fasb.org/extlink&oid=116825942&loc=d3e330215-122817 Reference 3: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 17 -Subparagraph (b) -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32809-109319 Reference 4: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section S99 -Paragraph 1 -Subparagraph (SAB TOPIC 6.I.5.Q1) -URI http://asc.fasb.org/extlink&oid=116825942&loc=d3e330036-122817 Reference 5: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 14 -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32705-109319 Reference 6: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 270 -Section 50 -Paragraph 1 -URI http://asc.fasb.org/extlink&oid=6424409&loc=d3e44925-109338 Reference 7: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -URI http://asc.fasb.org/topic&trid=2144680 Reference 8: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 30 -Section 50 -Paragraph 2 -Subparagraph (a) -URI http://asc.fasb.org/extlink&oid=6424122&loc=d3e41874-109331 + Details
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