10.    Income Taxes

The Company has established a full valuation allowance for its deferred tax assets based on management’s belief that it is not more likely than not that the related deferred tax assets will be realized.  For the three and nine months ended September 30, 2019 and 2018, there was no income tax expense or benefit.

At September 30, 2019 and December 31, 20187, the Company had no recorded tax liabilities for uncertain tax positions.  The Company has not yet filed any federal or state income tax returns for its stand-alone operations for years that are open for examination.  The Company does not expect any significant changes to the estimate amount of liabilities associated with uncertain tax positions in the next 12 months.

Pursuant to the Spin-off, the Company and Alliqua BioMedical, Inc. entered into a Tax Matters Agreement to provide for the payment of tax liabilities and entitlement of refunds; allocation of the responsibility for, and cooperation in, filing of tax returns; and other matters relating to taxes for the pre- and post-Spin-off periods.