LO.9, 10 Junior was a member of the Rice consolidated group for many years. It left the group effective for the 2012 tax year. In 2010, Junior sold a plot of land to Parent at a $600,000 realized loss. Recognition of that loss by the group was deferred under the matching rule. As a departing group member, does Junior have any right to take the loss with it to be used on its subsequent separate returns? Prepare two memos for the tax research file, outlining the arguments both in Junior’s favor and in the remaining group’s favor.