Graeter Corporation acquired all of stock of Lesser Corporation in 2009, and enities have filed a state and Federal consolidated income tax return ever since. In 2012, an audit notice from state unemployment tax administration makes it clear that Lesser underpaid its 2010 state and Federal payroll taxes by $2 million. Lesser's cash flow at this time is ppor and it has inadequate funds to pay the delinquent amount plus interest and penalties. Will the state revenue agency collect the outstanding payroll tax from graeter under Federal joint and numerous liability rules for tax obligation of consolidated return affiliates?