XML 35 R21.htm IDEA: XBRL DOCUMENT v3.21.1
Note 14 - Income Taxes
12 Months Ended
Dec. 31, 2020
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
Note
14.
    Income Taxes
 
Following is a summary of the components of the federal and state income tax expense (benefit) for each of the years in the
three
-year period ended
December 
31,
 
2020.
 
(In thousands)
 
Year Ended December 31,
 
   
2020
   
2019
   
2018
 
Current:
                       
Federal
  $
(100
)   $
88
    $
447
 
State
   
86
     
149
     
708
 
     
(14
)    
237
     
1,155
 
                         
Deferred:
                       
Federal
   
(2,448
)    
(698
)    
148
 
State
   
2,125
     
(438
)    
(413
)
     
(323
)    
(1,136
)    
(265
)
                         
Income tax (benefit) expense
  $
(337
)   $
(899
)   $
890
 
 
For each of the years in the
three
-year period ended
December 
31,
 
2020,
the difference between the federal statutory income tax rate and Patriot's effective income tax rate reconciles as follows:
 
(In thousands)
 
Year Ended December 31,
 
   
2020
   
2019
   
2018
 
                         
Income taxes at statutory Federal rate
  $
(873
)   $
(780
)   $
858
 
State taxes, net of Federal benefit
   
(191
)    
(228
)    
233
 
Deferred tax valuation allowance
   
1,938
     
-
     
-
 
Reversal UTP on Federal DTA
   
(1,132
)    
-
     
-
 
Nondeductible expenses
   
8
     
14
     
15
 
Benefit of change in Sec 382 classification
   
-
     
-
     
(500
)
Deferred tax adjustment resulting from tax rate change
   
-
     
-
     
198
 
Other
   
(87
)    
95
     
86
 
Income tax (benefit) expense
  $
(337
)   $
(899
)   $
890
 
 
The effective tax rate for the years ended
December 
31,
 
2020,
2019
and
2018
was
8.1%,
24.2%,
and
21.8%,
respectively.
 
The decrease in the effective tax rate for
2020
was primarily due to the recoding of a deferred tax asset valuation allowance. There were
no
significant changes to the effective tax rate for
2019
and
2018.
 
The effective tax rate for
2018
was impacted by the reduction in the statutory Federal corporate tax rate to
21%
from
34%
that was effective
January 1, 2018.
 
Deferred Tax Assets and Liabilities
The significant components of Patriot's net deferred tax assets at
December 
31,
 
2020
and
2019
are presented below.
 
(In thousands)
 
December 31,
 
   
2020
   
2019
 
Deferred tax assets:
 
 
 
 
 
 
 
 
Federal NOL carryforward benefit
  $
4,576
    $
4,759
 
NOL write-off for Sec 382 Limit
   
(3,258
)    
(3,258
)
Capitalized cost temporary item
   
3,627
     
3,929
 
State NOL carryforward benefit
   
3,306
     
3,341
 
Allowance for loan loss
   
3,869
     
2,718
 
Lease liabilities
   
775
     
882
 
Non-accrual interest
   
558
     
335
 
Merger and acquisition
   
204
     
220
 
Accrued expenses
   
201
     
114
 
Unrealized loss AFS securities
   
180
     
140
 
Share based compensation
   
8
     
13
 
Other
   
15
     
-
 
Gross deferred tax assets
   
14,061
     
13,193
 
Less deferred taxasset valuation allowance
   
(1,937
)    
-
 
Total deferred tax assets
   
12,124
     
13,193
 
                 
Deferred tax liabilities:
 
 
 
 
 
 
 
 
UTP (NOLs used)
   
-
     
(1,132
)
Right-of-Use assets
   
(736
)    
(849
)
Goodwill and intangible
   
170
     
(40
)
Depreciation of premises and equipment
   
(32
)    
(34
)
Other
   
(30
)    
(5
)
Gross deferred tax liabilities
   
(628
)    
(2,060
)
                 
Net deferred tax asset
 
 
11,496
   
 
11,133
 
 
As of
December 
31,
 
2020,
Patriot had available approximately
$21.8
million of Federal net operating loss carryforwards (“NOL”) that is offset by
$15.5
million in
§382
limitations imposed by the Internal Revenue Code. Of the NOL of
$21.8
 million, approximately
$20.2
million will expire between
2030
and
2033
and
$1.6
million which do
not
expire.
 
Patriot has approximately
$55.8
million of NOLs available for Connecticut tax purposes at
December 
31,
 
2020,
which
may
be used to offset up to
50%
of taxable income in any year. The NOLs expire between
2030
and
2039.
 
Valuation Allowance Against Net Deferred Tax Assets
Patriot uses the asset and liability method of accounting for income taxes. Under this method, deferred tax assets and liabilities are determined based on temporary differences between the financial statement and tax basis of assets and liabilities using enacted tax rates in effect for the year in which the differences are expected to reverse. The effect on deferred tax assets and liabilities of a change in tax laws is recognized in the consolidated statements of operations in the period that includes the enactment date.
 
Valuation allowances are established when necessary to reduce deferred tax assets to the amounts that are more likely than
not
expected to be realized based on the weighting of positive and negative evidence. Future realization of deferred tax assets ultimately depends on the existence of sufficient taxable income of the appropriate character (for example, ordinary income or capital gain) within the carryback or carryforward periods available under the applicable tax law. The Company regularly reviews the deferred tax assets for recoverability based on historical taxable income, projected future taxable income, the expected timing of the reversals of existing temporary differences and prudent and feasible tax planning strategies. The Company's judgments regarding future profitability
may
change due to many factors, including future market conditions and the ability to successfully execute its business plans. Should there be a change in the ability to recover deferred tax assets, the tax provision would increase or decrease in the period in which the assessment is changed. The valuation allowance at
December 31, 2020
was primarily related to state net operating losses. Patriot will continue to evaluate the need for valuation allowances for its deferred tax assets.
 
During
December 31, 2020,
Patriot recorded a partial valuation allowance of
$1.9
million primarily against its deferred tax asset related to state net operating loss carryforwards. For the year ended
December 31, 2020
Patriot was in a cumulative loss position. In order to overcome this negative evidence Patriot reviewed its accumulated pre-tax income(loss) for the current and prior
two
- and
three
-year periods and adjusted for non-recurring items. After the adjustments, Patriot was
no
longer in a cumulative loss position. Patriot used the average adjusted pre-tax income for the current and prior
three
years as the basis for objectively estimating future taxable income. Secondly, Patriot has a tax planning strategy available under ASC
740
that would be implemented to prevent a carry-forward state net operating losses from expiring. The strategy consists of capitalizing loan costs to increase income and avoid state net operating losses from expiring unused.
 
As deferred tax assets associated with NOL carryforwards are already a direct reduction to Tier
1
Capital, the valuation allowance at
December 31, 2020
had
no
impact on the Bank's regulatory capital position.
 
Unrecognized tax benefits
Patriot recognizes a benefit from its tax positions only if it is more likely than
not
that the tax position will be sustained on examination by taxing authorities, based on the technical merits of the position. The tax benefits recognized in the consolidated financial statements from such a position are measured based on the largest benefit that has a greater than
50%
likelihood of being realized upon ultimate settlement with a taxing authority that has full knowledge of all relevant information.
 
As of
December 
31,
 
2020
and
2019,
the Bank recorded an uncertain tax position related to the utilization of certain federal net operating losses of
$0
and
$1.2
million, respectively. At
December 31, 2020
Patriot
no
longer has a liability for unrecognized tax benefits. Additionally, Patriot has
no
pending or on-going audits in any tax jurisdiction.
 
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
 
(In thousands)
 
Year Ended December 31,
 
   
2020
   
2019
   
2018
 
Balance, beginning of year
  $
1,220
    $
1,132
    $
-
 
Increases due to tax positions related to a prior year
   
65
     
88
     
1,132
 
Decreases to tax positions as a result of a lapse of statute
   
(1,285
)    
-
     
-
 
Balance, end of year
  $
-
    $
1,220
    $
1,132
 
 
The Company's policy is to recognize interest and penalties related to income tax matters in income tax expense.
 
Patriot's returns for tax years
2017
through
2020
are subject to examination by the IRS for U.S. Federal tax purposes and, for State tax purposes, by the Department of Revenue Services for the State of Connecticut and the State of New York Department of Taxation and Finance.