General rule – ignore special values, what is it worth to particular taxpayer/recipient. Nixon – charge first class ticket.
Valuation problems – tough to figure out standard. Objective, subjective, incremental cost? House Ways and Means Committee Report of 1979 says “lowest price at which employee might reasonably have obtained comparable benefit in the same geographical area within a reasonable period of time.” Internet makes this somewhat outmoded.
Receipt of property – §83 –deals with property received for performance of services. Property has to be transferable and not subject to substantial risk of forfeiture before it can be taxed.
§83(c)(1) – substantial risk of forfeiture if rights to full enjoyment of property are conditioned on future performance of services.
§83(c)(2) – transferable only if transferee receives property without substantial risk of forfeiture.