In 2010,Jimmy,a cash basis taxpayer,was offered $3,000,000 for signing a professional baseball contract.He rejected the offer in favor of $900,000 per year for 4 years beginning in 2010.He collected $900,000 in 2010.Jimmy did not constructively receive $3,000,000 in 2010.

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Jimmy did not constructively receive $3,000,000 in 2010 because he rejected the offer in favor of receiving $900,000 per year for 4 years beginning in 2010. Therefore, he only received $900,000 in 2010 and did not have to report the $3,000,000 as income for that year.

In 2010,Jimmy,a Cash Basis Taxpayer,was Offered $3,000,000 for Signing a Professional