If the Administrator is paying the registry to process transfers...

If the Administrator is paying the registry to process transfers then no problem to do off market transfer, which I understand is the case with CMR.

Suggest you guys that need the write off find a mate (arms length) do the transfer for say a cent each and realise the loss. Make sure not to transfer back in a short period of time or ATO will knock your claim back.

When an entity is totally r-oted there is no funds to pay register and you can't do a transfer in this case, normally leads to liquidation, then liquidators does a declaration for tax purposes which enables you to realise loss, if nothing left over for shareholders it is 100% capital loss.
In this case you can't do anything until that declaration is made.

As with anything to do with ATO get proper professional advice