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