Sam is an independent contractor to Quick-save, a computer service company. Sam sells the company's services and is compensated for every sale he makes. Quick-save decided to terminate its relationship with Sam and as part of the termination, on December 5, 20x1, transferred to Sam 200 shares of its stock. Sam paid $100 per share for the stock. At the time of transfer each share of the stock had a fair market value of $100. The terms of the stock sale is that Sam can only keep the shares if he does not engage in competition in the geographic area where Same previously sold Quick-save services until December 5, 20x5. Quick-save is known to successfully sue those who have violated their non-compete clauses. Sam informs you of his purchase and the terms of his ownership in the stock a couple of days after the purchase. 

What would you advise Sam regarding the tax consequences of this situation and why?