id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-476	Cummings, Jr., Jasper L.	Zero Basis Hoax or Contingent Debt and Failure of Proof?. Sorting Out the Issues in the Lessinger Case	2022	43	.pdf	application/pdf	21121	993	59	In the section 357(c) context, Manning proposes viewing the obligation as an open purchase transaction that will provide stock basis to the transferor when it is paid in cash.3 The G.C.M. expressed concern about characterizing the transferor's obligation as a contract calling for future contributions to capital and about identifying the amount of stock basis acquired by transferor for his obligation.	cache/ftr-476.pdf	txt/ftr-476.txt