That would be too fair. I’m betting this plan disallows losses. Just like when you sell your house.
Pay on gains, no loss offset.
You may need to see a tax accountant. I was able to write-off losses on the sale of my house and if its a large enough loss, I believe you can span the losses for three years. Don't quote me on the particulars, I'm just going by memory of about 8 years ago.