Income Taxes (Restated)

12 Months Ended

Dec. 31, 2024

Income Tax Disclosure [Abstract]

Income Taxes (Restated)

Income Taxes (Restated)

Income tax expense consisted of the following:

	Year ended December 31,
	2024		2023		2022
Current taxes:
Federal	$	21,397,905	$	(187,842)	$	6,396,753
State	6,755,337		828,067		1,682,682
Deferred taxes:
Federal	(10,736,492)		(4,156,778)		4,292,445
State	(2,396,492)		(1,550,531)		719,025
Total income tax expense	$	15,020,258	$	(5,067,084)	$	13,090,905

In periods before our merger with Clinigence, Nutex Health Holdco LLC and the Nutex Subsidiaries were pass-through entities treated as partnerships for U.S. federal income tax purposes. No provision for federal income taxes was provided for these periods as federal taxes were obligations of these companies’ members. After the merger, Nutex Health Holdco LLC became a wholly-owned subsidiary of Clinigence and is included in its consolidated corporate tax filings. We recognized a non-cash charge of $21.3 million to income tax expense during 2022 for the change in tax status of Nutex Health Holdco LLC. This charge provides for the accumulated net deferred tax liabilities representing the differences between the book and tax bases of Nutex Health Holdco LLC’s assets and liabilities as of the April 1, 2022 change in tax status.

At the time of our merger with Clinigence, Clinigence had a full valuation allowance against its deferred tax assets. For the year ended December 31, 2022 we recorded a non-cash benefit of $2.4 million to income tax expense to remove the acquired valuation allowance after we concluded that the associated deferred tax assets would be realizable.

Each of the discrete items above, as well as the non-deductible goodwill impairment expense recognized in 2024, 2023 and 2022, are one-time, non-cash items.

The items accounting for differences between income taxes computed at the federal statutory rate and the provision recorded for income taxes were as follows:

	Year ended December 31,
	2024		2023		2022
Income taxes computed at the federal statutory rate	$	23,063,407	$	(10,183,068)	$	(88,126,230)
Effect of:
State taxes, net of federal benefits	5,804,488		(2,565,163)		(17,962,513)
Income of flow-through entities	(10,687,429)		(420,119)		(2,185,760)
Change in tax status of Nutex Health Holdco LLC	—		—		21,312,374
Change in valuation allowance	(6,537,550)		7,481,880		—
Reversal of acquired Clinigence valuation allowance	—		—		(2,393,178)
Non-deductible stock compensation	4,166,637		846,311		—
Non-deductible goodwill impairment expense	1,012,626		458,750		100,682,261
Worthless Stock deduction	(2,012,758)		—		—
Other, net	210,837		(685,675)		1,763,951
Total income tax expense	$	15,020,258	$	(5,067,084)	$	13,090,905

Deferred tax assets and liabilities were as follows:

	December 31,
	2024		2023
Deferred tax assets:
Net operating loss carryforwards	$	—	$	3,814,961
Capital loss carryforwards	944,330		1,344,478
Accrued liabilities	890,281		784,969
Accrued professional fees	6,904,165		—
ROU Liability	64,789,073		57,757,017
Stock-based compensation	393,500		393,442
Interest expense limitation	53,146		845,940
Other	560,894		523,980
Total deferred tax assets	74,535,389		65,464,787
Deferred tax liabilities:
Cash to accrual adjustments	(2,457,238)		(4,914,654)
Property and equipment	(7,073,690)		(6,726,315)
ROU Asset	(51,964,235)		(45,976,729)
Intangible assets	(3,910,385)		(5,164,445)
Other	(198,275)		(346,518)
Total deferred tax liabilities	(65,603,823)		(63,128,661)
Net deferred tax assets before valuation allowance	8,931,566		2,336,126
Valuation allowance	(944,330)		(7,481,880)
Net deferred tax assets (liabilities)	$	7,987,236	$	(5,145,754)

As of December 31, 2024 the Company fully utilized their federal and state net operating losses. The Company has a capital loss carryover of $4.5 million, that expires in 2025. Due to the uncertainty about the Company's ability to utilize the capital loss prior to the expiration date, the Company maintains a valuation allowance against that deferred tax asset.

As of December 31, 2024, the Company determined that is was more likely than not that it could generate sufficient future taxable income to fully recognize its net deferred tax assets (except as mentioned above). Accordingly, the Company reversed $6.5 million of the valuation allowance that it maintained at December 31, 2023.

As of December 31, 2023, a valuation allowance was established against the net deferred tax asset because the Company determined it was more likely than not that future earnings will not be sufficient to realize the corresponding tax benefits. In determining the appropriate valuation allowance, the Company considered the projected realization of tax benefits based on expected levels of future taxable income, available tax planning strategies and reversals of existing taxable temporary differences.