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Dear;

In an exchange qualifying for Sec. 351 tax-free treatment, Greta receives 100 shares of White Corporation stock plus a right to receive another 25 shares. The right is contingent on the valuation of a patent contributed by Greta. Because the patent license is pending, the patent cannot be valued for several months. Prepare a memorandum for your tax manager explaining whether the underlying 25 shares are considered “stock” for purposes of Sec. 351 and what tax consequences ensue from Greta’s receipt of the 100 shares now and 25 shares later upon exercise of the right.