Barriers to the application of the constructive receipt doctrine.

Tax Executive | January 1, 1989| | Copyright

Barriers to the Application of the Constructive Receipt Doctrine

I. Overview

The doctrine of constructive receipt --largely formulated by the courts, but also defined in the regulations(1) --complements the doctrine of actual receipt as a test of realization in that it prevents a cash-basis taxpayer from deliberately turning his back on income and thereby selecting the year in which he reports it.(2) Not recognizing the constructive receipt of income as realized income clearly would open the door to tax avoidance and, possibly, tax evasion.

The doctrine of constructive ...

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