CONSTRUCTIVE-RECEIPT DOCTRINE

glossary /

CONSTRUCTIVE-RECEIPT DOCTRINE

constructive-receipt doctrine. The rule that gross income under a taxpayer’s control before it is actually received (such as accumulated interest income that has not been withdrawn) must be included by the taxpayer in gross income, unless the actual receipt is subject to significant constraints. IRC (26 USCA) ¡ì 451. [Cases: Internal Revenue 3081.]
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