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Freda is a cash basis taxpayer. In 2019, she negotiated her salary for 2021. Her employer offered to pay her $21,000 per month in 2021

Freda is a cash basis taxpayer. In 2019, she negotiated her salary for 2021. Her employer offered to pay her $21,000 per month in 2021 for a total of $252,000. Freda countered that she would accept $10,000 each month for the 12 months in 2021 and the remaining $132,000 in January 2022. The employer accepted Fredas terms for 2021 and 2022.

  1. Did Freda actually or constructively receive $252,000 in 2021?

  2. What could explain Fredas willingness to spread her salary over a longer period of time?

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