9. Income Taxes

There was no income tax expense for the years ended December 31, 2014 2013 and 2012 due to the Company’s net losses.

The Company’s tax expense differs from the “expected” tax expense for the years ended December 31, 2014, 2013 and 2012 (computed by applying the Federal Corporate tax rate of 34% to loss before taxes and 3.96% for Michigan State Corporate taxes, the blended rate used was 37.96%), as follows (in thousands):

	2014			2013			2012
Tax expense/(benefit) at statutory rate – Federal	$	(6,727	)	$	(4,188	)	$	(5,803	)
Tax expense/(benefit) at statutory rate – State		(783	)		(488	)		(676	)
NOL carryforward adjustment per tax return		(687	)		—			—
Meals, entertainment and other		13			6			5
Non-deductible stock-based compensation		789			511			518
Fair Market Value adjustment – Warrants		(235	)		—			—
Change in valuation allowance		7,630			4,159			5,956
	$	—		$	—		$	—

The effects of temporary differences that gave rise to significant portions of deferred tax assets at December 31, 2014 and 2013 are as follows (in thousands):


	2014			2013
Deferred tax assets:
Stock issued for services	$	585		$	441
Bad debt – change in allowance		—			1,099
Stock issued for acquisition of program		949			652
Stock issued for license agreement		2,507			2,707
Net operating loss carry-forward		24,657			16,168
Total gross deferred tax assets		28,698			21,067
Less valuation allowance		(28,698	)		(21,067	)
Net deferred tax assets	$	—		$	—

At December 31, 2014, the Company has a net operating loss carry-forward of approximately $65.2 million available to offset future taxable income expiring through 2034. However, utilization of these net operating losses may be limited due to potential ownership changes under Section 382 of the Internal Revenue Code.

The valuation allowance at December 31, 2013 was approximately $21.1 million. The net change in valuation allowance during the year ended December 31, 2014 was an increase of approximately $7.6 million. In assessing the realizability of deferred 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 generation of future taxable income during the periods in which those temporary differences become deductible. Management considers the scheduled reversal of deferred income tax liabilities, projected future taxable income, and tax planning strategies in making this assessment. Based on consideration of these items, management has determined that enough uncertainty exists relative to the realization of the deferred income tax asset balances to warrant the application of a full valuation allowance as of December 31, 2014.

ASC 740-10 “Accounting for Uncertain Tax Positions” prescribes a recognition threshold and measurement attribute for the financial statement recognition and measurement of a tax position taken or expected to be taken in a tax return and also provides guidance on de-recognition, classification, interest and penalties, accounting in interim periods, disclosure, and transition.

As of December 31, 2014 and 2013, the Company had no unrecognized tax benefits and no adjustments to liabilities or operations were required under ASC 740-10. The Company’s practice was and continues to be to recognize interest and penalty expenses related to uncertain tax positions in income tax expense, which was zero for the years ended December 31, 2014 and 2013. The Company files United States federal and various state income tax returns.

The Company is routinely subject to examinations by taxing authorities in these various jurisdictions. The Company’s U.S. tax matters for the years 2000 through 2014 remain subject to examination by the Internal Revenue Service due to the Company’s NOL carryforwards. The Company’s U. S. tax matters remain subject to examination by various state and local tax jurisdictions due to our NOL carryforwards.

The Company does not anticipate that it is reasonably possible that unrecognized tax benefits as of December 31, 2014 will significantly change within the next 12 months.