Freda is a cash basis taxpayer. In 2021, she negotiated her salary for 2022. Her employer offered to pay her $21,000 per month in 2022 for a total of $252,000. Freda countered that she would accept $10,000 each month for the 12 months in 2022 and the remaining $132,000 in January 2023. The employer accepted Freda’s terms for 2022 and 2023.

a. Did Freda actually or constructively receive $252,000 in 2022?

b. What could explain Freda’s willingness to spread her salary over a longer period of time?