Here's the textbook explanation: (see Reg. 1.1032-1(a) & Rev. Rule 62-217, 1962-2 C.B. 59, modified by Rev. Rul. 74-503, 1974-2 C.B. 117)

STOCK ISSUED FOR SERVICES RENDERED

A transfer of stock for services is not a taxable transaction to a corporation. But another issue arises: Can a corp deduct the FMV of the stock it issues in consideration of services as a busines expense? Yes, unless the services are such that the payment is characterized as a capital expenditure.

Example 23: Esther and Carl form White Corp. Esther transfers cash of $500,000 for 100 shares of White Corp stock. Carl transfers property worth $400,000 (basis of $90,000) and agrees to serve as manager of the corp for one year; in return, Carl receives 100 shares of stock in White. The value of Carl's services to White Corp is $100,000. Esther's and Carl's transfers qualify under Sec. 351. Neither Esther nor Carl is taxed on the transfer of their property. However, Carl has income of $100,000, the value of the stock received for the services he will render to White Corp. White has a basis of $90,000 in the property it acquired from Carl, and it may claim a compensation expense deduction under Sec. 162 for $100,000. Carl's stock basis is $190,000 [$90,000 (basis of property transferred) + $100,000 (income recognized for services rendered.)].

Example 24: Assume the same facts as in Example 23 except that Carl provides legal services (instead of management services) in organizing the corp. The value of Carl's legal services is $100,000. Carl has no gain on the transfer of the property but has income of $100,000 for the value of the stock received for the services rendered. White Corp has a basis of $90,000 in the property it acquired from Carl and must capitalize the $100,000 as an organizational expenditure. Carl's stock basis is $190,000 [$90,000 (basis of property transferred) + $100,000 (income recognized for services rendered)].

If the above text and examples doesn't clarify the treatment, I can look at the CCH textbook for their explanation. The above is from the South-Western Federal Taxation.