Updated July 29, 2026. Quick answer: Not for that reason — but the timing question matters more than the reason. Treas. Reg. §1.83-2(f) allows revocation only with the Commissioner’s consent, and a mistake as to value or a decline in value is not a ground. Rev. Proc. 2006-31 adds the part almost nobody mentions: consent “will generally be granted if the request is filed on or before the due date for making that §83(b) election” — 30 days after the transfer. After day 30, the price answer governs and it is no.
Two rules, and the order to read them in
Rev. Proc. 2006-31, §2.08: “The Internal Revenue Service has recognized the principle that an election made under the Code or regulations may be revoked on or before the due date for making the election … Accordingly, a request for consent to revoke a §83(b) election will generally be granted if the request is filed on or before the due date for making that §83(b) election.”
Three qualifiers ride on that, and dropping any of them misleads. The due date is the one in IRC §83(b)(2) — 30 days after the property was transferred, not 30 days after you filed. Filing on day three does not buy you until day 33. And the word is generally granted, which states a general rule rather than an entitlement. And it is not a form you send: §4.01 requires the request “be made under the procedures for requesting a letter ruling”, with its own submission requirements and user fee.
Treas. Reg. §1.83-2(f) governs everything after that date: an election “may not be revoked except with the consent of the Commissioner,” and “consent will be granted only in the case where the transferee is under a mistake of fact” as to the underlying transaction, requested within 60 days of discovering it. The regulation excludes two categories expressly: a mistake as to the value, or decline in the value, of the property, or a failure to perform an act contemplated at the time of the transfer. Changing your mind about a plan is no more a mistake of fact than the price falling is.
| Situation | Revocable? |
|---|---|
| Any reason, request filed within 30 days of the transfer | Generally yes — Rev. Proc. 2006-31 §2.08 |
| The stock fell, day 31 or later | No — expressly excluded |
| You misjudged the value, day 31 or later | No — expressly excluded |
| You left before vesting and forfeited | No — a later event, not a mistake at filing |
| Genuine mistake of fact about the transaction | Possible, with consent, within 60 days of discovery |
So the practical answer is a calendar answer. The window in which second thoughts are cheap is the same 30 days in which the election itself must be made. Once it closes, the election is a completed bet: you have paid ordinary tax at the transfer value, and Treas. Reg. §1.83-4(a) has started your capital-gains holding period “just after the date such property is transferred” rather than at vesting. If the appreciation never arrives, that is the risk the rules contemplate and decline to unwind.
Filing mechanics
Treas. Reg. §1.83-2(c) requires filing one copy of a written statement with the internal revenue office where you file your return — but that is only the filing step. The same regulation also prescribes what the statement must contain and requires a copy to reach the person for whom the services were performed, so read §1.83-2 in full rather than this summary of it. Rev. Proc. 2012-29 supplies sample language that “may be used (but is not required to be used)”, and the IRS now publishes Form 15620 (Rev. 4-2025) for the election, a three-page document whose pages two and three are its instructions. An election on a standard RSU was never available: Treas. Reg. §1.83-3(e) defines property to exclude “an unfunded and unsecured promise to pay money or property in the future.”
The deferral election built for illiquid private stock is §83(i) — and there is a specific reason your employer probably does not offer it.
Sources
IRC §83(a), §83(b)(1) and (b)(2); Treas. Reg. §1.83-2(c) and §1.83-2(f); Rev. Proc. 2006-31, §2.03 and §2.08 with its Examples; Rev. Proc. 2012-29; Treas. Reg. §1.83-3(e) and §1.83-4(a); IRS Form 15620 (Rev. 4-2025), form face and instructions. Read July 2026.
This states what the cited authority says. It is not tax, legal or investment advice. Lock-up terms, award agreements and plan documents vary, and both the securities and the tax analysis turn on facts about your role and holdings that no page can see.