P and S Corporations form in Year 1, with S as P’s wholly-owned subsidiary. The corporations immediately elect to file consolidated tax returns. The group reports the following results:

In what year(s) can the group deduct the Year 2 consolidated NOL? Assume that Year 2 is a post-2017 year.

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Taxable Income Group Member Year 1 Year 2 Year 3 Year 4 $9,000 $20,000 $21,000 $25,000 (7,800) (30,000) (16,000) P S 2,000 Consolidated taxable income (before NOL deduction) $1,200 $(10,000) $ 5,000 $27,000