Freda is a cash basis taxpayer. In 2022, she negotiated her salary for 2023. Her employer offered

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Freda is a cash basis taxpayer. In 2022, she negotiated her salary for 2023. Her employer offered to pay her $21,000 per month in 2023 for a total of $252,000. Freda countered that she would accept $10,000 each month for the 12 months in 2023 and the remaining $132,000 in January 2024. The employer accepted Freda’s terms for 2023 and 2024.

a. Did Freda actually or constructively receive $252,000 in 2023?

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

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South Western Federal Taxation 2023 Comprehensive Volume

ISBN: 9780357719688

46th Edition

Authors: Annette Nellen, Andrew D. Cuccia, Mark Persellin, James C. Young

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