Question Circumstances are;

1. Founder has formed a c-corp, now wanting to issue shares to management team partners.
2. 16 Million share are registered for a California securities exemption.
3. No shares have been sold yet.
4. First founder that formed the c-corp owns all shares now.
5. First founder wants to issue shares to partners now at a value of 0.0001 or something low like that.
6. The partners get shares and start working and the c-corp then sale shares to investors for a dollar a share.
7. The event of the investors shares being sold I think established a value only when that event takes place.
8. The new partners file 83b election while shares are low

The question is, is there any chance the IRS will say the value existed at the time partners got the shares at the low price? If the investor?s shares are sold for a dollar per share just weeks or a month after partner shares are sold a fraction of a penny, then can the IRS assess tax on the partners based on what the investors paid?