Guest jig Posted June 10, 2003 Posted June 10, 2003 In a nonqualified deferred comp situation, is termination for cause and voluntary termination by the Employee enough to constitute substantial risk of forfeiture under Code Section 83?
Guest svatty Posted June 11, 2003 Posted June 11, 2003 Burnetta v. Comm., 68 TC 387 (1977) provides that it is well settled that the risk of a forfeiture that would be triggered by an employee discharge for cause or for committing a crime is not considered substantial for purposes of Section 83. I also believe there are some PLR's on point.
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