Which of the Following Is True with Regard to the Holding

Which of the following is true with regard to the holding in the United Steel v. Manhart case?

A) United Steel was the plaintiff.
B) Shares can be issued by a Texas corporation in exchange for the promise of future services.
C) Shares can be issued by a Texas corporation only if there is a completed conveyance of real estate to the corporation by the recipient of the shares.
D) Only preferred shares can be issued in exchange for the promise of future services.
E) The promise of future services cannot be the basis for issuing shares to the promisor.