8. Income Taxes

There was no income tax expense for the years ended December 31, 2015 and 2014 due to the Company’s net losses. The Company’s tax expense differs from the “expected” tax expense for the years ended December 31, 2015 and 2014 (computed by applying the Federal Corporate tax rate of 34% to loss before taxes and 3.96% for blended state income tax rate, the blended rate used was 37.96%), as follows (in thousands):

	2015			2014
Computed “expected” tax-benefit – Federal	$	(14,870	)	$	(6,727	)
Computed “expected” tax-benefit – State		(1,732	)		(783	)
Adjustment of “expected” tax-benefit to actual		199			(687	)
Meals, entertainment and other		8			13
Non-deductible stock-based compensation		877			789
Fair Market Value Adjustment – Warrants		1,447			(235	)
Change in valuation allowance		14,071			7,630
	$	—		$	—

The effects of temporary differences that gave rise to significant portions of deferred tax assets at December 31, 2015 and 2014 are as follows (in thousands):

Deferred tax assets:	2015			2014
Stock issued for services	$	922		$	585
Accrued compensation		105			—
Stock issued for acquisition of program		1,787			949
Stock issued for license agreement		2,308			2,507
Net operating loss carry-forward		37,852			24,657
Total gross deferred tax assets		42,974			28,698
Less: valuation allowance		(42,974	)		(28,698	)
Total net deferred tax assets	$	—		$	—

At December 31, 2015, the Company has a net operating loss carry-forward of approximately $99.4 million available to offset future taxable income expiring through 2035. 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, 2014 was approximately $28.7 million. The net change in valuation allowance during the year ended December 31, 2015 was an increase of approximately $14.1 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, 2015.

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, 2015 and 2014, 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, 2015 and 2014. 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, 2015 will significantly change within the next 12 months.