PRIVILEGED AND CONFIDENTIAL

PRIVILEGED AND CONFIDENTIAL
CALDERWOOD & HARKNESS LLP
1735 Market Street, Suite 3100 Philadelphia, PA 19103 Telephone: (215) 864-7200 Facsimile: (215) 864-7201
600 Lexington Avenue New York, NY 10022 Telephone: (212) 596-4000 Facsimile: (212) 596-4001
www.calderwoodharkness.com
October 25, 2023
C&H Matter No. 1018-00009
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA SECURE E-FAX
Supervisory Revenue Agent Gerald Meskill, Team Manager Large Business & International Division Internal Revenue Service 600 Arch Street, Room 6318 Philadelphia, PA 19106
Revenue Agent Patricia Dunleavy, Lead Revenue Agent Large Business & International Division Internal Revenue Service 600 Arch Street, Room 6318 Philadelphia, PA 19106
Re:  Penterra Pharmaceuticals Corp. Employer Identification Number: 22-3741856 Exam Team ID: LB&I-NE-TP-2022-00641 Tax Years Under Examination: 2017, 2018, 2019, 2020 Notice of Proposed Adjustment Dated October 12, 2023
Dear Mr. Meskill and Ms. Dunleavy:
I. IDENTIFICATION OF COUNSEL AND ACKNOWLEDGMENT OF RECEIPT
Calderwood & Harkness LLP ("Calderwood & Harkness" or the "Firm") represents Penterra Pharmaceuticals Corp. ("PPC" or the "Company"), a Delaware corporation headquartered at 2200 Independence Boulevard, Princeton Junction, New Jersey 08550, Employer Identification Number 22-3741856, whose shares are publicly traded on the Nasdaq Stock Market under the ticker symbol PPCA. Our representation of PPC in connection with this examination and all related matters has been authorized pursuant to IRS Form 2848 (Power of Attorney and Declaration of Representative) filed with the Internal Revenue Service on June 8, 2022, a copy of which is enclosed herewith for your reference. The Form 2848 designates the following Calderwood & Harkness attorneys as authorized representatives of PPC: Leonard Cross (CAF No. 1832-47291R), Sylvia Hartwell (CAF No. 1832-58103R), Garrett Simmons (CAF No. 1832-62488R), and Leila Nazari (CAF No. 1832-63019R). Our engagement as counsel to PPC with respect to this examination has been in effect since June 2, 2022.
We write to acknowledge receipt by PPC of the Notice of Proposed Adjustment ("NOPA") dated October 12, 2023, which was received by PPC on or about October 14, 2023. The NOPA was issued in connection with the ongoing examination of PPC's federal income tax returns for Tax Year 2017, Tax Year 2018, Tax Year 2019, and Tax Year 2020 (collectively, the "Examination Years"). We respectfully request that all future correspondence, notices, and communications pertaining to this examination be directed to the undersigned as PPC's authorized representative, in accordance with the Form 2848 on file.
This letter constitutes PPC's initial response to the NOPA and sets forth a summary of the proposed adjustments, a statement of PPC's position with respect to those adjustments, a reservation of PPC's rights and defenses, and certain procedural requests, including a request for an extension of time to file a formal Protest. PPC's comprehensive response to the factual, legal, and economic bases for the proposed adjustments will be set forth in detail in the formal Protest to be filed following issuance of the 30-Day Letter.
II. SUMMARY OF THE NOPA AND PROPOSED ADJUSTMENTS
The NOPA proposes adjustments under Section 482 of the Internal Revenue Code of 1986, as amended ("IRC" or the "Code"), to PPC's transfer pricing for intercompany transactions with its Irish subsidiary, Penterra Biopharma International DAC ("PBI"). PBI is a Designated Activity Company organized and existing under the laws of Ireland, with its registered office at 4th Floor, Claremont House, Sandyford Business Park, Dublin D18 K7T4, Ireland. PBI is a wholly owned subsidiary of PPC, held indirectly through Penterra Holdings Luxembourg S.à r.l. ("PH Lux"), a Luxembourg private limited liability company. PH Lux is treated as a disregarded entity for United States federal income tax purposes, and accordingly, for purposes of the IRC § 482 analysis, the relevant controlled transactions are those between PPC and PBI.
The NOPA proposes adjustments in two principal categories — cost-sharing arrangement adjustments and royalty rate adjustments — together with a correlative offset to avoid double-counting, as well as the assertion of a penalty under IRC § 6662(e). Each is summarized below.
A. Cost-Sharing Arrangement Adjustments
The first category of proposed adjustments relates to the qualified cost-sharing arrangement ("CSA") between PPC and PBI, which has been in effect since July 1, 2012, and is governed by Treasury Regulation § 1.482-7. Under the CSA, PPC and PBI share the costs of qualified research and development activities in proportion to their respective reasonably anticipated benefits ("RAB") from the intangible property expected to be developed under the arrangement.
The IRS proposes to increase PBI's cost-sharing percentages under the CSA for each of the Examination Years, asserting that PPC's projections of reasonably anticipated benefits materially understated the value of U.S.-source benefits, thereby resulting in an understatement of PBI's share of qualified R&D costs. Specifically, the proposed adjustments to PBI's cost-sharing percentages, and the resulting dollar adjustments to income allocable to PPC, are as follows:
The IRS's position, as set forth in the NOPA, is that PPC's RAB projections systematically overstated the proportion of future benefits expected to accrue to PBI and understated the proportion of future benefits expected to accrue to PPC from intangibles developed under the CSA. The IRS contends that the economic analysis supporting PPC's RAB percentages failed to account adequately for U.S.-source value, including the contribution of U.S.-based clinical development, regulatory expertise, and commercial infrastructure to the overall value of the developed intangible property.
B. Royalty Rate Adjustments
The second category of proposed adjustments relates to the intercompany royalty rate applicable to legacy intangible property licensed by PPC to PBI. PPC licensed certain pre-existing intellectual property to PBI at a royalty rate of 4.5% of PBI's non-Americas net sales. The IRS proposes to increase this royalty rate from 4.5% to 11.0%, citing comparable uncontrolled transaction ("CUT") data analyzed under Treasury Regulation § 1.482-4. The IRS asserts that the CUT method applied by PPC undervalues the licensed intangible property relative to the comparables identified in the IRS's analysis.
The resulting proposed adjustments for each of the Examination Years are as follows:
The NOPA references what the examination team characterizes as CUT comparables drawn from third-party pharmaceutical licensing transactions in the areas of oncology and immunology. PPC's position regarding the comparability — or lack thereof — of these purported CUTs will be addressed at length in PPC's formal Protest.
C. Correlative Offset
The NOPA allows a correlative offset of $42,650,000 in the aggregate across the four Examination Years to avoid double-counting between the CSA cost-sharing adjustments and the royalty rate adjustments. This offset reflects the IRS's acknowledgment that certain portions of the proposed CSA and royalty adjustments would otherwise result in overlapping income allocations to PPC.
D. Total Proposed Net Adjustment
The total proposed net adjustment across all four Examination Years is calculated as follows:
CSA Adjustments (Subtotal): $235,010,000
Royalty Rate Adjustments (Subtotal): $188,032,000
Less: Correlative Offset: ($42,650,000)
Net Proposed Adjustment: $380,392,000
For purposes of this letter, we refer to the net proposed adjustment as approximately $380.40 million.
E. Proposed Penalty — Substantial Valuation Misstatement
In addition to the proposed income adjustments, the NOPA asserts a substantial valuation misstatement penalty under IRC § 6662(e) at the 20% rate, calculated on the tax attributable to the net IRC § 482 allocation. The NOPA calculates the proposed penalty as follows:
Net § 482 Adjustment: $380,400,000
Tax Rate: 21%
Tax Attributable to Adjustment: $79,884,000
Penalty Rate: 20%
Proposed Penalty: Approximately $15,976,800
PPC vigorously disputes the assertion of any penalty, as discussed further below.
F. Economic Substance Challenge
The NOPA additionally asserts that PBI lacks sufficient economic substance to justify its role as an intellectual property owner and CSA participant. The IRS contends that key Development, Enhancement, Maintenance, Protection, and Exploitation ("DEMPE") functions with respect to the intangible property at issue remained in the United States and were performed by PPC's U.S.-based personnel and operations, such that PBI should not be treated as the beneficial owner of the intangible property interests attributed to it under the CSA and the legacy IP license. This challenge forms a significant component of the IRS's analytical framework underlying the proposed adjustments and is inextricably linked to the CSA and royalty adjustments described above. PPC fundamentally disagrees with this characterization, as set forth in Section III below.
III. STATEMENT OF PPC'S POSITION — DISAGREEMENT WITH THE NOPA
PPC respectfully but firmly disagrees with each of the proposed adjustments and the asserted penalty set forth in the NOPA. PPC's comprehensive factual, legal, and economic response to the NOPA will be presented in its formal Protest, but PPC sets forth the following summary of its position to ensure that the examination team is fully apprised of PPC's objections at this stage of the proceedings.
A. Compliance with the Arm's-Length Standard
PPC maintains that its transfer pricing methodology for both the CSA cost-sharing percentages and the legacy intellectual property royalty rate fully complies with the arm's-length standard under IRC § 482 and the applicable Treasury Regulations, including Treasury Regulation §§ 1.482-1 (general provisions), 1.482-4 (methods applicable to transfers of intangible property), and 1.482-7 (cost-sharing arrangements). PPC's intercompany pricing for each of the Examination Years was established using the best method under the circumstances, was supported by robust economic analysis, and produced results consistent with those that would have been obtained between uncontrolled taxpayers dealing at arm's length.
B. Cost-Sharing Arrangement — Reasonably Anticipated Benefits
The CSA cost-sharing ratios reported by PPC (ranging from 38.2% for Tax Year 2017 to 42.7% for Tax Year 2020) were determined on the basis of reasonably anticipated benefits, as required by Treasury Regulation § 1.482-7(e)(1). These ratios were developed through a rigorous economic analysis that incorporated PBI's projected share of worldwide benefits from the intangible property expected to be developed under the CSA, using a methodology consistent with the requirements of the regulations and informed by detailed financial projections, market analyses, and pipeline assessments. The RAB analysis was prepared contemporaneously with the filing of each year's return and was reviewed and updated annually.
PPC submits that the IRS's proposed increases to PBI's cost-sharing percentages are not supported by the facts, are inconsistent with the regulatory framework governing RAB calculations, and reflect a fundamental misunderstanding of the respective roles and contributions of PPC and PBI within the CSA. PPC will demonstrate in its Protest that its RAB methodology and the resulting cost-sharing ratios fall squarely within the arm's-length range.
C. Legacy intellectual Property Royalty Rate
The 4.5% royalty rate for legacy intellectual property licensed to PBI was established using the CUT method under Treasury Regulation § 1.482-4(c). PPC identified and analyzed comparable uncontrolled pharmaceutical license agreements, and the 4.5% rate is within the arm's-length range as demonstrated by those comparables. The IRS's proposed increase to 11.0% relies on purported CUT comparables that PPC believes are materially distinguishable from the PPC–PBI license on multiple grounds, including the nature and stage of the licensed technology, the scope of rights granted, the allocation of development risk, the geographic scope of the license, and the relative bargaining positions of the parties. PPC will present a detailed comparability analysis in its Protest demonstrating that the IRS's proposed royalty rate is not supported by reliable comparable transactions.
D. Platform Contribution Transaction Valuation
Furthermore, PPC notes that the platform contribution transaction ("PCT") payment of $312,000,000 made on July 1, 2012, upon the inception of the CSA, properly valued the pre-existing intangible property contributed by PPC to the CSA, in accordance with Treasury Regulation § 1.482-7(g). The PCT payment was supported by a contemporaneous valuation performed using the income method under Treasury Regulation § 1.482-7(g)(5) and is within the arm's-length range. To the extent the NOPA's adjustments implicitly challenge the adequacy of the PCT valuation, PPC maintains that the PCT amount was appropriate and consistent with the arm's-length standard.
E. Economic Substance of PBI — DEMPE Functions
PPC strongly disputes the IRS's contention that PBI lacks sufficient economic substance to justify its role as an IP owner and CSA participant. The record developed during the examination, including PPC's responses to forty-seven (47) Information Document Requests ("IDRs"), demonstrates that PBI possesses genuine economic substance and performs substantive DEMPE functions. Among the facts supporting PBI's economic substance are the following:
•  PBI employs approximately 185 full-time employees at its offices in Dublin, Ireland, including scientists, regulatory affairs professionals, commercial operations managers, and senior executives with extensive pharmaceutical industry experience.
•  PBI's board of directors held forty-two (42) meetings during the period covered by the Examination Years, at which substantive business decisions — including decisions regarding product development priorities, regulatory strategy, pricing, and commercial operations — were made and documented.
•  PBI incurred cumulative regulatory expenditures of approximately €47.2 million during the Examination Years in connection with obtaining and maintaining marketing authorizations and regulatory approvals across multiple jurisdictions outside the Americas.
•  PBI exercises independent pricing authority and makes independent commercial decisions across sixty-eight (68) country markets in which it distributes and sells pharmaceutical products, with pricing determinations made by PBI's commercial teams in Dublin in coordination with local distributors and in compliance with applicable regulatory pricing frameworks.
PPC will provide comprehensive evidence of PBI's DEMPE functions, organizational structure, human capital, decision-making authority, and operational activities in its formal Protest, including employee headcount data, organizational charts, board minutes, regulatory filings, and detailed functional analyses.
F. Contemporaneous Transfer Pricing Documentation and Penalty Defense
PPC maintained contemporaneous transfer pricing documentation for all four Examination Years, prepared in accordance with the requirements of IRC § 6662(e)(3)(B) and Treasury Regulation § 1.6662-6. This documentation was prepared by Crestfield & Associates LLP, an independent transfer pricing and economic consulting firm engaged by PPC for this purpose. The documentation sets forth the methodology, economic analyses, comparability analyses, and supporting data upon which PPC relied in establishing its intercompany transfer prices and CSA cost-sharing ratios for each of the Examination Years. PPC provided this documentation to the examination team in response to IDR No. 3, dated August 15, 2022, within thirty (30) days of the request.
PPC submits that the existence and quality of this contemporaneous documentation establishes a reasonable-cause and good-faith defense to the assertion of any penalty under IRC § 6662(e), as provided in IRC § 6662(e)(3)(B). PPC further submits that it reasonably relied on the analysis and conclusions of Crestfield & Associates LLP, a qualified and experienced transfer pricing consulting firm, in establishing its transfer pricing positions for the Examination Years. PPC will present a detailed defense to the asserted penalty in its formal Protest.
IV. RESERVATION OF RIGHTS
PPC expressly reserves all rights, defenses, arguments, and claims available to it under applicable law, regulation, treaty, and procedure, including but not limited to:
(a) The right to challenge all proposed adjustments set forth in the NOPA on factual, legal, and economic grounds, including the right to present alternative transfer pricing methodologies, comparability analyses, and economic evidence;
(b) The right to present additional evidence, analyses, expert reports, and testimony not previously submitted during the examination, including but not limited to expert economic testimony and industry benchmarking analyses;
(c) The right to contest the asserted substantial valuation misstatement penalty under IRC § 6662(e) on all available grounds, including reasonable-cause and good-faith reliance on contemporaneous transfer pricing documentation under IRC § 6662(e)(3)(B), as well as any other applicable penalty defenses under IRC § 6664;
(d) The right to seek correlative and conforming adjustments, including but not limited to adjustments to PBI's cost-sharing obligations, royalty deductions, and withholding tax obligations, as well as any corresponding adjustments necessary to prevent double taxation;
(e) The right to pursue competent authority relief under Article 25 (Mutual Agreement Procedure) of the Convention Between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed November 28, 1997, as amended (the "U.S.-Ireland Income Tax Treaty"), and any applicable Revenue Procedures governing competent authority requests;
(f) The right to petition the United States Tax Court under IRC § 6213 following the issuance of a statutory notice of deficiency, or to pursue any other available judicial remedy;
(g) All other rights, remedies, and defenses available under the Internal Revenue Code, the Treasury Regulations, applicable tax treaties, and the Internal Revenue Manual, including all procedural and substantive rights afforded to taxpayers during the examination, Appeals, and litigation processes.
Nothing in this letter, or in any prior or future communication by or on behalf of PPC, shall be construed as a concession, waiver, or abandonment of any position, right, defense, or argument available to PPC. PPC's decision not to address any particular issue or argument in this initial response letter does not indicate agreement with the IRS's position on that issue and shall not be deemed an admission or concession of any kind.
V. REQUEST FOR EXTENSION OF TIME TO FILE FORMAL PROTEST
PPC acknowledges that the 30-Day Letter accompanying the NOPA, which PPC anticipates will be issued pursuant to standard IRS procedures set forth in the Internal Revenue Manual, will afford PPC the opportunity to file a formal written Protest and request consideration of the proposed adjustments by the IRS Independent Office of Appeals.
PPC respectfully requests an extension of the deadline for filing its formal Protest. The complexity of the issues presented in the NOPA is exceptional, spanning four tax years and involving multiple transfer pricing methodologies — including cost-sharing arrangement analysis under Treasury Regulation § 1.482-7, the comparable uncontrolled transaction method under Treasury Regulation § 1.482-4(c), and platform contribution transaction valuation under Treasury Regulation § 1.482-7(g) — as well as extensive economic analyses and the IRS's challenge to PBI's economic substance and DEMPE functions. The preparation of a comprehensive and responsive Protest necessitates substantial time for legal research, economic analysis, factual development, and coordination among PPC's advisors.
In addition, the volume of the examination record underscores the complexity of this matter. During the course of the examination, the IRS examination team issued forty-seven (47) Information Document Requests between June 2022 and September 2023, to which PPC provided extensive documentary responses. The preparation of PPC's Protest will require a thorough review of this extensive record to ensure that all relevant facts and analyses are accurately presented and that PPC's position is supported by the full evidentiary record.
Further, PPC must coordinate the preparation of its Protest with its economic consultants, Whitmore Valuation Group LLC ("Whitmore"), which has been retained under a Kovel arrangement to assist in the preparation of PPC's economic analysis and transfer pricing defense. Dr. Helena Vasquez of Whitmore serves as lead economist and is currently preparing a comprehensive economic analysis in response to the IRS's proposed adjustments. PPC must also coordinate with its Irish tax advisors, Thornbury & Keogh, Dublin, regarding the Irish tax implications of the proposed adjustments and potential competent authority proceedings.
In light of the foregoing, PPC formally requests that the deadline for filing its formal Protest be extended from the standard thirty (30) calendar days following issuance of the 30-Day Letter to December 22, 2023. PPC submits that this extension will allow it to file a thorough, complete, and well-supported Protest, which in turn will facilitate efficient and productive consideration of the disputed issues by IRS Appeals and, ultimately, a timely resolution of this matter.
PPC expresses its willingness to discuss the extension request and any alternative timeline at the convenience of the examination team. PPC's counsel is available to arrange a telephone conference or in-person meeting to discuss the logistics of the Protest submission and any related scheduling matters.
VI. STATUTE OF LIMITATIONS
PPC is aware of the applicable statute of limitations for the assessment of additional tax for each of the Examination Years. PPC notes that it has previously executed IRS Form 872 (Consent to Extend the Time to Assess Tax) for Tax Year 2017 and Tax Year 2018, extending the period of assessment for those years through December 31, 2024. With respect to Tax Year 2019 and Tax Year 2020, PPC understands that the original assessment periods remain open under the standard three-year period provided by IRC § 6501(a), as potentially extended by the six-year period under IRC § 6501(e) where applicable.
PPC expresses its willingness to discuss any further extensions of the statute of limitations that may be necessary to accommodate the filing of PPC's formal Protest and the Appeals process, subject in all cases to PPC's review and agreement on the scope and terms of any such consent. PPC confirms its intention to cooperate fully and in good faith throughout the remainder of the examination and any subsequent proceedings before the IRS Independent Office of Appeals.
VII. COORDINATION WITH IRS CHIEF COUNSEL
PPC acknowledges its awareness that attorneys from the IRS Office of Chief Counsel have been involved in the preparation of the proposed adjustments and the NOPA. Specifically, PPC understands that Attorney-Advisor Franklin Rosario and Senior Counsel Donna Hirabayashi of the IRS Office of Chief Counsel have participated in the development of the legal positions set forth in the NOPA. PPC respects the role of Chief Counsel in providing legal guidance to the examination team.
PPC respectfully requests that all future communications regarding legal positions, legal analyses, and legal authorities relating to the proposed adjustments and the pending examination be coordinated through Calderwood & Harkness LLP as PPC's authorized representatives. This request is made to ensure the orderly and efficient exchange of information and to protect PPC's procedural rights throughout the examination and any subsequent proceedings.
VIII. REQUEST FOR COPY OF IRS ECONOMIST'S REPORT
PPC respectfully requests that the examination team provide PPC with a copy of, or access to, the complete economic analysis prepared by IRS economist Dr. Alan Washburne of the IRS Transfer Pricing Practice that underlies and supports the proposed adjustments set forth in the NOPA, to the extent such analysis or any portion thereof has not already been provided to PPC during the course of the examination. PPC understands that Dr. Washburne prepared economic analyses addressing both the CSA cost-sharing percentages and the royalty rate adjustments, including the identification and analysis of purported CUT comparables and the RAB projections utilized by the IRS.
Access to the IRS economist's complete report and supporting analyses is essential to PPC's ability to prepare a responsive and comprehensive Protest, to evaluate the economic basis for the IRS's proposed adjustments, and to develop PPC's own responsive economic analyses through its retained economic consultants at Whitmore Valuation Group LLC. PPC submits that the disclosure of the IRS economist's report will serve the interests of both parties in facilitating an informed and productive exchange of positions, both during the remaining stages of the examination and in any subsequent Appeals proceedings.
IX. CLOSING
PPC reiterates its firm belief that its transfer pricing positions for all four Examination Years are well-supported by the facts, applicable law, and robust economic analysis, and that those positions comply fully with the arm's-length standard of IRC § 482 and the applicable Treasury Regulations. PPC is confident that a thorough review of the facts and applicable authorities will demonstrate that no adjustment to PPC's reported intercompany transfer prices is warranted and that the assertion of the IRC § 6662(e) penalty is without merit.
PPC remains committed to working constructively and cooperatively with the examination team and, as appropriate, with the IRS Independent Office of Appeals, to resolve the issues raised in the NOPA in a manner that is consistent with the facts and applicable law. PPC values the professionalism of the examination team and looks forward to a continued productive dialogue as this matter proceeds.
We respectfully request confirmation of receipt of this letter and of PPC's request for an extension of time to file its formal Protest. Please direct all correspondence, communications, and inquiries regarding this matter to:
Leonard Cross, Partner Calderwood & Harkness LLP 1735 Market Street, Suite 3100 Philadelphia, PA 19103 Direct Telephone: (215) 864-7218 Direct Facsimile: (215) 864-7219
Email: lcross@calderwoodharkness.com
Copies of this letter are being provided to Sylvia Hartwell, Garrett Simmons, and Leila Nazari at Calderwood & Harkness LLP.
We thank you for your attention to this matter and remain available to discuss any questions or scheduling matters at your convenience.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Leonard Cross Partner
On behalf of Penterra Pharmaceuticals Corp.
cc: (via email and U.S. mail)
Marcus Whitfield, Vice President, Global Tax Penterra Pharmaceuticals Corp. 2200 Independence Boulevard Princeton Junction, NJ 08550
Deborah Staines, General Counsel Penterra Pharmaceuticals Corp. 2200 Independence Boulevard Princeton Junction, NJ 08550
Sylvia Hartwell, Partner Calderwood & Harkness LLP
Garrett Simmons, Associate Calderwood & Harkness LLP
Leila Nazari, Associate Calderwood & Harkness LLP
Encl.: Copy of IRS Form 2848 (Power of Attorney and Declaration of Representative), filed June 8, 2022
Tax Year | PPC's Reported PBI Share | IRS Proposed PBI Share | Increase (Percentage Points) | Total Qualified R&D Costs | Adjustment Amount
2017 | 38.2% | 48.2% | +10.0 pp | $487,300,000 | $48,730,000
2018 | 39.6% | 50.6% | +11.0 pp | $523,800,000 | $57,610,000
2019 | 41.1% | 52.3% | +11.2 pp | $561,200,000 | $62,850,000
2020 | 42.7% | 53.7% | +11.0 pp | $598,400,000 | $65,820,000
Subtotal | $235,010,000
Tax Year | Non-Americas Net Sales (PBI) | Royalty Differential (6.5%) | Adjustment Amount
2017 | $814,600,000 | 6.5% | $52,949,000
2018 | $762,300,000 | 6.5% | $49,549,500
2019 | $691,800,000 | 6.5% | $44,967,000
2020 | $624,100,000 | 6.5% | $40,566,500
Subtotal | $188,032,000