Reference no: EM132832202

Inigo Montoya goes to work for Vizzini, Inc. and is granted stock options as part of his incentive package. The stock is traded on an established securities market. On January 1, 2017, Vizzini transfers to Inigo 30,000 shares of substantially non-vested stock in Vizzini. At the time of the transfer, the shares have an aggregate fair market value of $60,000. Inigo pays Vizzini $30,000 in exchange for the stock.

• The stock agreement states that if Inigo stops working for Vizzini, Inc. as an employee prior to January 1, 2019, Inigo will forfeit the stock back to Vizzini who will reimburse him the amount he paid for the stock. So January 1, 2019 is the date the shares are fully vested and Inigo no longer faces forfeiture if he stops working for Vizzini. On the vesting date of Jan. 1, 2019, the stock has a fair market value of $90,000.

• On August 14, 2019, Inigo sells the stock for $102,000.

Problem 1: What are the tax consequences of all the transactions if Inigo does not make a valid §83(b) election?

Problem 2: What are the tax consequences if Inigo does make a timely valid §83(b) election?