Return to the facts of problem 66. If the stock is subject to substantial restrictions, what are the tax consequences for both Louise and Somerton on the date Louise is granted the stock option and the date she exercises the option, assuming that she does not make a Section 83(b) election? How would your answer change if she makes a Section 83(b) election and the fair market value of the stock when the restrictions lapse on March 31, 2012, is $22?