12. Income Taxes

The components of the income tax provision for the three and six months ended June 30, 2017 and 2016 are as follows:

	Three Months Ended		Three Months Ended		Six Months Ended		Six Months Ended
	June 30, 2017		June 30, 2016		June 30, 2017		June 30, 2016
	(unaudited)		(unaudited)		(unaudited)		(unaudited)
Current:
Federal	$	4,699	$	—	$	10,184	$	—
State		51,838		32,972		100,240		84,362
		56,537		32,972		110,424		84,362
Deferred:
Federal		118,061		403,358		217,419		8,133
State		21,885		76,497		40,577		(15,748	)
		139,946		479,855		257,996		(7,615	)
	$	196,483	$	512,827	$	368,420	$	76,747

A reconciliation of the statutory federal income tax provision to the Company’s income tax provision is as follows:

	Three Months Ended			Three Months Ended			Six Months Ended			Six Months Ended
	June 30, 2017			June 30, 2016			June 30, 2017			June 30, 2016
	(unaudited)			(unaudited)			(unaudited)			(unaudited)
Statutory federal income tax provision	$	446,175		$	846,728		$	1,492,659		$	884,057
Effect of non-taxable REIT income		(323,416	)		(224,433	)		(1,265,057	)		(738,696	)
State income tax provision (benefit)		73,724			(109,468	)		140,818			(68,614	)
	$	196,483		$	512,827		$	368,420		$	76,747

As of June 30, 2017 and December 31, 2016, we had a net deferred tax asset of approximately $6.7 million and $6.9 million, respectively, of which, approximately $5.8 million and $6.0 million, respectively, are due to accumulated net operating losses of our TRS Lessee. These loss carryforwards will begin to expire in 2028 if not utilized by such time. As of both June 30, 2017 and December 31, 2016, approximately $0.2 million of the net deferred tax asset is attributable to our share of start-up expenses related to the Crowne Plaza Hollywood Beach Resort, start-up expenses related to the opening of the Sheraton Louisville Riverside and the Crowne Plaza Tampa Westshore that were not deductible in the year incurred, but are being amortized over 15 years. The remainder of the net deferred tax asset is attributable to year-to-year timing differences including accrued, but not deductible, employee performance awards, vacation and sick pay, bad debt allowance and depreciation.

We record a valuation allowance to reduce deferred tax assets to an amount that we believe is more likely than not to be realized. Because of expected future taxable income of our TRS Lessee, we have not recorded a valuation allowance to reduce our net deferred tax asset as of June 30, 2017 and December 31, 2016, respectively. We regularly evaluate the likelihood that our TRS Lessee will be able to realize its deferred tax assets and the continuing need for a valuation allowance. At June 30, 2017 and December 31, 2016, we determined, based on all available positive and negative evidence, that it is more-likely-than-not that future taxable income will be available during the carryforward periods to absorb all of the consolidated federal and state net operating loss carryforward of our TRS Lessee. A number of factors played a critical role in this determination, including:

•

a demonstrated track record of past profitability and utilization of past NOL carryforwards,

•

reasonable forecasts of future taxable income, and

•

anticipated changes in the lease rental payments from the TRS Lessee to subsidiaries of the Operating Partnership.