Prior to the completion of the Mergers on December 27, 2019 (as described in Note 1 under the heading “—Merger with MedAmerica Properties Inc.”), the Company was structured as a limited liability company and was treated as a partnership for U.S. federal and state income purposes. As such, any taxes incurred prior to the Mergers are the responsibility of the members, and accordingly no provisions for federal or state income taxes were recorded for the Company. The income tax benefit consisted of the following for the year ended December 31, 2019 (dollars in thousands):

	Year Ended December 31, 2019
Current:
Federal	$	-
State		-
Total current tax expense (benefit)		-
Deferred:
Federal	$	(502	)
State		(202	)
Total deferred tax benefit		(704	)
Total income tax benefit	$	(704	)

The Company’s effective income tax rate for the years ended December 31, 2019 and December 31, 2018 reconciles with the federal statutory rate as follows:

	Year Ended December 31, 2019			Year Ended December 31, 2018
Federal statutory rate		21.0	%		21.0	%
Loss attributable to partnership not subject to tax		-11.6	%		-21.0	%
State income taxes, net of federal tax benefit		2.8	%		0.0	%
Effective income tax rate on income before taxes		12.2	%		0.0	%

The difference between the Company’s effective tax rate and federal statutory rate for 2019 is 8.8% which is primarily due to permanent items and state taxes.

Deferred income tax liabilities are comprised of the following at December 31, 2019 (dollars in thousands):

	Year Ended December 31, 2019
Investment in the Operating Partnership	$	(14,707	)
NOL Carryforwards		57
Total deferred tax liabilities	$	(14,650	)

At December 31, 2019, the Company has federal and state income tax NOL carryforwards of approximately $0.2 million which will carry forward indefinitely subject to annual taxable income limitations.

The Company had no uncertain tax positions as of December 31, 2019. Generally, for federal and state purposes, the Company's 2016 through 2019 tax years remain open for examination by tax authorities. Additionally, any net operating losses that were generated in prior years and utilized in these years may also be subject to examination by the IRS. The Company’s policy is to recognize interest and penalties associated with uncertain tax positions as part of income tax expense.