Darryll K. Jones (Pittsburgh) has published Back to the Future with Forfeiture Allocations, 108 Tax Notes 1457 (Sept. 19, 2005), also available on the Tax Analysts web site as Doc 2005-18365, 2005 TNT 181-42. Here is part of the Introduction:

The concept of "forfeiture allocations" is the most intriguing feature of the proposed service partner regulations. Forfeiture allocations apply when a service partner makes an 83(b) election (and thus becomes an "83(b) partner") with respect to a partnership interest obtained as compensation for services, and then later forfeits the interest. The apparent goal of forfeiture allocations is to retroactively erase the 83(b) partner’s existence and then recast past events as if the 83(b) partner never even existed. Allocations made to the 83(b) partner are reversed and those reversed partnership items are allocated back to the original partners. To consider that to be going "back to the future" is not entirely accurate because, in some instances, forfeiture allocations do not completely restore the reality that would have been if the 83(b) partner never existed. Under the proposed regulations, forfeiture allocations sometimes take us only partially back to the future. The subtle paradox is more than rhetorical. It is implicit in the IRS’s internal debate, about which the Service seeks comment, regarding the extent to which forfeiture allocations should operate.