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INCOME TAXES
3 Months Ended
Mar. 31, 2020
INCOME TAXES  
INCOME TAXES

6.    INCOME TAXES

The Company’s earnings (losses), other than those generated by the Company’s TRS, are not generally subject to federal corporate and state income taxes due to the Company’s REIT election. The Company did not pay any federal and state income taxes for the periods ended March 31, 2020 and 2019. The Company did not have any uncertain tax positions as of March 31, 2020 or December 31, 2019.

The Company’s TRS generated a net operating loss (“NOL”) for the three months ended March 31, 2020 and the year ended December 31, 2019, which can be carried forward to offset future taxable income. As of March 31, 2020 and December 31, 2019, the Company had a recorded deferred tax asset of $813,724 and $205,808, respectively, primarily attributable to its NOLs generated in the current period and prior periods, net of temporary differences primarily related to depreciation. The Company’s NOLs will expire in 2038‑2039 for state tax purposes and will not expire for federal tax purposes. As of March 31, 2020, the tax years 2018 and 2019 remain subject to examination by the U.S. Internal Revenue Service (“IRS”) and various state tax jurisdictions.

The Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), passed in March 2020, allows for NOL’s arising in tax years beginning after December 31, 2017 and before January 1, 2021 to be carried back to each of the preceding 5-year periods.  In addition, the CARES Act removed the 80% absorption limitation previously enacted under the Tax Cuts and Jobs Act of 2017.  Generally unused NOL’s generated prior to 2018 will expire 20 years following the year in which the NOL was created.