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