7. Income Taxes

For federal income tax purposes, as well as for state income tax purposes in the majority of the states in which the Partnership operates, the earnings attributable to the Partnership and the Operating Partnership are not subject to income tax at the partnership level. With the exception of those states that impose an entity-level income tax on partnerships, the taxable income or loss attributable to the Partnership and to the Operating Partnership, which may vary substantially from the income (loss) before income taxes reported by the Partnership in the consolidated statement of operations, are includable in the federal and state income tax returns of the Common Unitholders. The aggregate difference in the basis of the Partnership’s net assets for financial and tax reporting purposes cannot be readily determined as the Partnership does not have access to each Common Unitholder’s basis in the Partnership.

As described in Note 1 and Note 2, the earnings of the Corporate Entities are subject to corporate level federal and state income tax. However, based upon past performance, the Corporate Entities are currently reporting an income tax provision composed primarily of minimum state income taxes. A full valuation allowance has been provided against the deferred tax assets based upon an analysis of all available evidence, both negative and positive at the balance sheet date, which, taken as a whole, indicates that it is more likely than not that sufficient future taxable income will not be available to utilize the assets. Management’s periodic reviews include, among other things, the nature and amount of the taxable income and expense items, the expected timing of when assets will be used or liabilities will be required to be reported and the reliability of historical profitability of businesses expected to provide future earnings. Furthermore, management considered tax-planning strategies it could use to increase the likelihood that the deferred tax assets will be realized.

The income tax provision of all the legal entities included in the Partnership’s consolidated statement of operations, which is composed primarily of state income taxes in the few states that impose taxes on partnerships and minimum state income taxes on the Corporate Entities, consists of the following:


	Year Ended
	September 27, 2014		September 28, 2013		September 29, 2012
Current
Federal	$	10	$	26	$	18
State and local		757		581		119

		767		607		137
Deferred		—		—		—

	$	767	$	607	$	137

The provision for income taxes differs from income taxes computed at the United States federal statutory rate as a result of the following:


	Year Ended
	September 27, 2014			September 28, 2013			September 29, 2012
Income tax provision at federal statutory tax rate	$	33,346		$	27,792		$	271
Impact of Partnership income not subject to federal income taxes		(38,919	)		(35,187	)		(4,564	)
Permanent differences		86			71			244
Transfer of assets to Corporate Entities		—			—			8,181
Change in valuation allowance		5,458			9,771			(3,567	)
State income taxes		(60	)		(1,135	)		339
Other		856			(705	)		(767	)

Provision for income taxes—current	$	767		$	607		$	137

The components of net deferred taxes and the related valuation allowance using currently enacted tax rates are as follows:


	As of
	September 27, 2014			September 28, 2013
Deferred tax assets:
Net operating loss carryforwards	$	51,321		$	46,356
Allowance for doubtful accounts		1,371			878
Inventory		433			525
Intangible assets		122			577
Deferred revenue		1,524			2,188
Derivative instruments		71			109
AMT credit carryforward		1,086			1,086
Other accruals		2,060			2,062

Total deferred tax assets		57,988			53,781

Deferred tax liabilities:
Property, plant and equipment		6,124			7,375

Total deferred tax liabilities		6,124			7,375

Net deferred tax assets		51,864			46,406
Valuation allowance		(51,864	)		(46,406	)

Net deferred tax assets	$	—		$	—

After the Inergy Propane Acquisition, the Partnership contributed all of the Inergy Propane assets and liabilities to the Operating Partnership which, in turn, contributed the fuel oil and refined fuels and service assets and liabilities to the Corporate Entities. At the time of the transfer, the Corporate Entities recognized a deferred tax liability for the difference between the book basis of the assets received and their tax basis. The recognition of that deferred tax liability was offset by the release of a portion of the valuation allowance that previously existed on the net deferred tax assets. Thus, the transfer of these assets had no impact on net income for fiscal 2012.