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Text of Rev. Rul. 2005-48: Recognition of Sec. 83 Income Despite 16(b) and Contractual Restrictions
Internal Revenue Service [IRS] 
[Official Guidance] Aug. 2, 2005
Guidance regarding which provisions of the Securities Exchange Act of 1934 delay taxation under section 83 of the Code and whether temporary contractual restrictions on the transfer of section 83 property cause rights in the property to be substantially nonvested. The IRS also announced that, except for cases arising under the jurisdiction of the First Circuit, the Service will not follow the decision in Robinson v. Comm'r., 805 F.2d 38 (1st Cir. 1986), reversing 82 T.C. 444 (1984).
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