NOTE 20. INCOME TAXES

Total income tax benefit (expense) are summarized as follows:


	Year ended December 31,
	2019		2018		2017
Income Tax (Expense) Benefit from Continuing Operations	$	(5,472,178)	$	(6,025,148)	$	22,481,523
Income Tax (Expense) Benefit from Discontinued Operations		(32,641,194)		(7,529,596)		(12,546,257)
Total Consolidated Income Tax Benefit (Expense)	$	(38,113,372)	$	(13,554,744)	$	9,935,266

The provisions for income tax benefit (expense) from continuing operations are summarized as follows:


	2019				2018				2017
	Current		Deferred		Current		Deferred		Current		Deferred
Federal	$	(225,495)	$	(4,973,699)	$	(231,239)	$	(5,380,837)	$	1,729,007	$	18,959,360
State		19,998		(292,982)		(127,470)		(285,602)		153,234		1,639,922
Total	$	(205,497)	$	(5,266,681)	$	(358,709)	$	(5,666,439)	$	1,882,241	$	20,599,282

Deferred tax assets and liabilities are recognized for the future tax consequences attributable to the differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases and operating loss and tax credit carryforwards. Deferred tax assets and liabilities are measured using enacted tax rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled. The effect on deferred tax assets and liabilities of a change in tax rates is recognized in income in the period that includes the enactment date.

The sources of these differences and the related deferred income tax assets (liabilities) are summarized as follows:


	Deferred Tax
	2019		2018
Deferred Income Tax Assets
Depreciation	$	4,785,992	$	4,904,976
Intangible Lease Liabilities		6,503,574		7,111,608
Income Property Tenant Contributions		732,172		1,069,882
Impairment Reserves		92,751		1,393,415
Stock Options and Restricted Stock		1,274,694		977,210
Capital Loss Carryforward		20,750		20,750
Deferred Oil Lease Income		—		121,323
Other - Net		6,638		44,967
Gross Deferred Income Tax Assets		13,416,571		15,644,131
Less - Valuation Allowance		(272,966)		(272,966)
Net Deferred Income Tax Assets		13,143,605		15,371,165
Deferred Income Tax Liabilities
Sales of Real Estate		(87,353,465)		(67,388,733)
Income Property Lease Incentive		—		(606,820)
Discount on Equity Component of Convertible Debt		(42,400)		(238,200)
Basis Differences in Joint Ventures		(11,789,044)		(764,566)
Basis Difference in Alpine Income Property OP, LP		(3,979,966)		—
Interest Rate Swap		(73,924)		(486,543)
Deferred Revenue (Net of Straight-line Rent Adjustments)		(186,979)		(578,034)
Other - Net		—		(78,176)
Total Deferred Income Tax Liabilities		(103,425,778)		(70,141,072)
Net Deferred Income Tax Liabilities	$	(90,282,173)	$	(54,769,907)

In assessing the realizability of deferred income tax assets, Management considers whether it is more likely than not that some portion or all of the deferred income tax assets will not be realized. The ultimate realization of deferred income tax assets is dependent upon the realization of future taxable income during the periods in which those temporary differences become deductible. We consider past history, the scheduled reversal of taxable temporary differences, projected future taxable income, and tax planning strategies in making this assessment. As of December 31, 2019 and 2018, we believe it is more likely than not that a portion of the Company’s deferred income tax assets will not be realized, and accordingly, a valuation allowance has been provided. As of December 31, 2019 and 2018, the valuation allowance was approximately $273,000.

As of December 31, 2019 and 2018, the valuation allowance relates solely to a basis difference in a joint venture with a wholly owned and fully consolidated subsidiary, and no valuation allowance is provided for charitable contribution carryforwards due to the expectation of full utilization during 2019.

Following is a reconciliation of the income tax computed at the federal statutory rate of 21% for 2019 and 2018 and 35% for 2017 for continuing operations:


	Year ended December 31,
	2019		2018		2017
Income Tax (Expense) Benefit Computed at Federal Statutory Rate	$	(4,410,318)	$	(4,557,366)	$	245,168
Increase (Decrease) Resulting from:
State Income Tax, Net of Federal Income Tax Benefit		(1,075,960)		(1,363,007)		39,677
Income Tax on Permanently Non-Deductible Items		(85,842)		(31,466)		66,015
Change in Corporate Federal Tax Rate		—		—		22,249,536
Other Reconciling Items		99,942		(73,309)		(118,873)
Benefit (Expense) for Income Taxes	$	(5,472,178)	$	(6,025,148)	$	22,481,523

The effective income tax rate for each of the three years ended December 31, 2019, 2018, and 2017, including income taxes attributable to the discontinued operations, was 24.9%, 26.7%, and (31.0)%, respectively. The provision for income taxes reflects the Company’s estimate of the effective rate expected to be applicable for the full fiscal year, adjusted for any discrete events, which are reported in the period that they occur. During the fourth quarter of 2017, the Company recorded an income tax benefit of approximately $22.2 million due to the impact of the reduction in the corporate tax rate from 35% to 21% for the Tax Cuts and Jobs Act.

The Company files a consolidated income tax return in the United States Federal jurisdiction and the States of Alabama, Arizona, Colorado, California, Florida, Georgia, Maryland, Massachusetts, Nevada, New Mexico, New York, North Carolina, Oregon, Texas, Virginia, Washington, and Wisconsin. The Internal Revenue Service has audited the federal tax returns through the year 2012, with all proposed adjustments settled. The Florida Department of Revenue has audited the Florida tax returns through the year 2014, with all proposed adjustments settled. The Company recognizes all potential accrued interest and penalties to unrecognized tax benefits in income tax expense. For the years ended December 31, 2019, 2018, and 2017 the Company recognized no uncertain tax positions or accrued interest and penalties for uncertain tax positions.

Income taxes totaling approximately $2.5 million, $323,000, and $334,000 were paid during the years ended December 31, 2019, 2018, and 2017, respectively. Additionally, income taxes totaling approximately $687,000, $204,000 and $958,000 were refunded during the years ended December 31, 2019, 2018, and 2017, respectively.