You're correct in your analysis. You'd be required to pay tax on the income received based upon the value of the stock (the object received is always going to

You're correct in your analysis. You'd be required to pay tax on the income received based upon the value of the stock (the object received is always going to determine the value or income you've received). A Section 83(b) election doesn't apply in this situation because of the stock isn't restricted under Title 26 of the United States Code. Restricted in the tax code means that it is either (a) undeterminable in value or (b) legal right to title or authority has not been transfered. You seem to have a perfect understanding of the issue. =)