Russ has never recognized any Sec. 1231 gains or losses. In December 2006, Russ is considering the sale of two Sec. 1231 assets. The sale of one asset will result in a $20,000 Sec. 1231 Gain while the sale of the other asset will result in a $20,000 Sec. 1231 loss. Russ has no other capital or Sec. 1231 gains and losses in 2006. He is aware that it might be advantageous to recognize the Sec. 1231 gain and the Sec. 1231 loss in different tax years. However, he does not know whether he should recognize the Sec. 1231 gain in 2006 and the Sec. 1231 loss in 2007 or vice versa. His marginal tax rate for each year is expected to be 33%. Advice the taxpayer with respect to these two alternatives:

a. Recognize the $20,000 Sec. 1231 loss in 2006 and the $20,000 Sec. 1231 gain in 2007.

b. Recognize the $20,000 Sec. 1231 gain in 2006 and the $20,000 Sec. 1231 loss in 2007.