83(b) election

the situation:
a private, early stage company, dormant for a few years since
the client owned 100% of their shares for 2+ years. there was no
vesting, and thus no 83(b) election was made at that time.
now, 2 years on, these shares will be subject to repurchase over time
(essentially a vesting provision for 4 years).
what are the 83(b)-related issues now? will the client have to pay
taxes as the the repurchase right lapses?
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