In 2014,Juan,a cash basis taxpayer,was offered $3 million for signing a professional baseball contract.He counter offered that he would receive $900,000 per year for 4 years beginning in 2015.The team accepted the counteroffer.Juan constructively received $3 million in 2014.

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The income was not constructively received in 2014 by Juan because he did not have the right to receive the income in that year.The $3 million offer was merely part of Juan's contract negotiations.

In 2014,Juan,a Cash Basis Taxpayer,was Offered $3 Million for Signing