On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Larson v. Commissioner (T.C. Memo. 2022-3). The primary issue presented in Larson was whether stock in an S corporation was subject to a substantial risk of forfeiture. Held: Nope. Background (and not a Particularly Flattering One for the petitioner) in Larson v. Commissioner Mr. Larson is a criminal. That’s not my opinion. That was the decision of the Southern District of New York in 2009, which sentenced him to 121 months in prison for tax evasion, three years of supervised release, and a fine. According to the Department of Justice, John Larson, a former senior manager at KPMG (Curly), and Robert Pfaff, a former partner at KPMG (Moe), were the founders and partners in an "investment advisor" firm for various tax shelter products. Along with R.J. Ruble, a partner at the law firm of Brown &…