Upon graduation, T signed a contract to play professional football.The contract contains the team's unsecured promise to pay T $500,000, $200,000 to be paid in his rookie year, with the remaining $300,000 deferred over the next three years.Assuming all other requirements are satisfied, the constructive receipt doctrine would require inclusion of the full $500,000 in income this year, since T was able to control the timing of receipt through a contractual arrangement.
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