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Probably the signature is not contemporaneous with receipt of the newly-created shares. With this hypothetical we do not see the ordinary “pro rata” accounting for change of cost basis in property held by members of the common enterprise equitably, we see individual choice+action
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That’s how ordinary splits are taxed, but here we have a hypothetical requirement for the taxpayer to take an action. The issuer is receiving something of non-zero economic value (a signature on a document from a shareholder) and in return the shareholder takes future possession
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