In 2011, employee E receives 10 shares of the common stock of his employer, Beta Corporation, as compensation.However, E will have to return the shares if he leaves his position with Beta before 2012.If E does not make a § 83(b) election with regard to the shares

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Without a § 83(b) election, E will not recognize income upon receipt of the stock in 2011 because the stock is subject to a substantial risk of forfeiture until 2012. Income is recognized when the stock vests (becomes not subject to forfeiture) if no § 83(b) election is made.

In 2011, Employee E Receives 10 Shares of the Common