Pony, Inc, Issues Restricted Stock to Employees in July 2017, with with a Two-Year

Multiple Choice

Pony, Inc., issues restricted stock to employees in July 2017, with a two-year vesting period and an SRF. An employee must remain a full-time employee of Pony for two years after the restricted stock is issued. The stock is trading at $10 per share when Sam is issued 1,000 shares, and he proceeds to make a § 83(b) election. At the end of 2017, the stock is selling for $13 per share. Sam remains a full-time employee of Pony for the required two-year vesting period at which time the stock is worth $30 per share. Sam sells his 1,000 shares in 2021 at $36 per share. What amount and type of income will Sam recognize in 2021?

A) $26,000 capital gain.
B) $26,000 ordinary income.
C) $23,000 capital gain.
D) $23,000 ordinary income.
E) $36,000 capital gain.