Hm, I thought IRS treated stock purchased with a non-recourse note as an option (since there's no risk to the employee). If that's true, then you can't take the

Hm, I thought IRS treated stock purchased with a non-recourse note as an option (since there's no risk to the employee). If that's true, then you can't take the 83b election. That is, unless you convert to a full recourse note, but then you're back to the employee cash liability thing again.