Murr, Joe, Sal and Quinn decide to form a corporation, Impractical Jokers, Inc. The company will manufacture and sell numerous products including the Cantenna and the 47 Hour Energy Bar. Murr, Sal and Quinn all contribute cash to Impractical Jokers, Inc. and they all receive 100 shares in return. Joe contributes cash and the patent for the 47 Hour Energy Bar and receives 100 shares of stock currently plus a right to receive an additional 25 shares. The right to receive the additional 25 shares is contingent on the patent controlled by Joe. Because the patent license is pending, the patent cannot be valued for several months. Joe is confused and is seeking your expert tax advice. Write a letter to Joe Gatto in the required memo format with your answers to how Joe should treat the 100 shares now and the additional 25 shares in the future for tax purposes. You should find at least one rule of law for each of the three categories listed below: A. Legislative Authority- The Internal Revenue Code (IRC) B. Administrative Authority- Regulations, Revenue Rulings C. Judicial Authority- Court Cases *Recommended Analysis Section paragraph* 1) State the issue trying to be resolved 2) Cite the rule of law then summarize the rule of law 3) Bring in facts from the Statement of Facts section that are relevant to the rule of law 4) Apply the law to the facts by stating if the facts meet or do not meet the requirements of the rule of law 5) Come to a conclusion (or if citing more law in a following paragraph, indicate where uncertainty exists and how more law is needed to come to a conclusion)