Did freda actually or constructively receive

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Freda is a cash basis taxpayer. In 2011, she negotiated her salary for 2012. Her employer offered to pay her a total of $250,000 for the year. Freda countered that she would accept $10,000 each month for the 12 months in 2012, and the remaining $130,000 in January 2013. The employer accepted Freda's terms for 2012 and 2013.

a) Did Freda actually or constructively receive $250,000 in 2012?
b) What could explain Freda's willingness to spread her salary over a longer period of time?

Reference no: EM13132656

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