Constructive Receipt
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Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ...
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Income Tax
An income tax is a tax imposed on individuals or entities (taxpayers) in respect of the income or profits earned by them (commonly called taxable income). Income tax generally is computed as the product of a tax rate times the taxable income. Taxation rates may vary by type or characteristics of the taxpayer and the type of income. The tax rate may increase as taxable income increases (referred to as graduated or progressive tax rates). The tax imposed on companies is usually known as corporate tax and is commonly levied at a flat rate. Individual income is often taxed at progressive rates where the tax rate applied to each additional unit of income increases (e.g., the first $10,000 of income taxed at 0%, the next $10,000 taxed at 1%, etc.). Most jurisdictions exempt local charitable organizations from tax. Income from investments may be taxed at different (generally lower) rates than other types of income. Credits of various sorts may be allowed that reduce tax. Some jurisdicti ...
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United States Tax Court
The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court". The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule" ...
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Davis V
Davis may refer to: Places Antarctica * Mount Davis (Antarctica) * Davis Island (Palmer Archipelago) * Davis Valley, Queen Elizabeth Land Canada * Davis, Saskatchewan, an unincorporated community * Davis Strait, between Nunavut and Greenland * Mount Davis (British Columbia) United States * Davis, California, the largest city with the name * Davis, Illinois, a village * Davis, Massachusetts, an abandoned mining village * Davis, Maryland, a ghost town * Davis, Missouri, an unincorporated community * Davis, North Carolina, an unincorporated community and census-designated place * Davis, Oklahoma, a city * Davis, South Dakota, a town * Davis, West Virginia, a town * Davis, Logan County, West Virginia, an unincorporated community * Davis Island (Connecticut) * Davis Island (Mississippi) * Davis Island (Pennsylvania) * Davis Peak (Washington) * Fort Davis, Oklahoma * Mount Davis (California) * Mount Davis (New Hampshire) * Mount Davis (Pennsylvania) Other * ...
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Hornung V
Hornung is a surname. Notable people with the surname include: * Clarence P. Hornung (1899–1998), American graphic designer *Dirk Hornung, German curler * Erik Hornung (born 1933), German Egyptologist *Ernest William Hornung (1866–1921), British author *Joe Hornung (1857–1931), American baseball player *Larry Hornung (1945–2001), Canadian ice hockey player *Otto Hornung R.P.S.L. (1920–2013), philatelist, postal historian and member of the Czecho-Slovak Legion in Poland and Russia 1939–1945 *Paul Hornung (1935–2020), American football player * Pitt Hornung (1869–1940), Sugar entrepreneur It was also a Frankish name for the month of February, introduced by Charlemagne; see . See also * Operation Hornung Operation Hornung was an anti-partisan operation during the Occupation of Belarus by Nazi Germany, carried out in February 1943. It was directed against the area Hancewicze- Morocz-Lenin-Łuniniec, a thinly populated area of about 4,000 square k ..., a 1943 Nazi s ...
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Paul Hornung
Paul Vernon Hornung (December 23, 1935 – November 13, 2020), nicknamed "the Golden Boy", was an American professional football player who was a Hall of Fame running back for the Green Bay Packers of the National Football League (NFL) from 1957 to 1966. He played on teams that won four NFL titles and the first Super Bowl. He is the first Heisman Trophy winner to be selected as the first overall selection in the NFL Draft, play pro football, win the NFL most valuable player award, and be inducted into both the professional and college football halls of fame. Packers coach Vince Lombardi stated that Hornung was "the greatest player I ever coached." A versatile player, Hornung was a halfback, quarterback, and placekicker. He was an excellent all-around college athlete at Notre Dame, where he played basketball in addition to football. Early years Hornung born and raised in Louisville, Kentucky. He was an outstanding athlete at Flaget High School in Louisville, and lettered ...
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Green Bay Packers
The Green Bay Packers are a professional American football team based in Green Bay, Wisconsin. The Packers compete in the National Football League (NFL) as a member club of the National Football Conference (NFC) NFC North, North division. It is the third-oldest franchise in the NFL, dating back to 1919, and is the only Nonprofit organization, non-profit, Community ownership, community-owned Major professional sports teams of the United States and Canada, major league professional sports team based in the United States. Home games have been played at Lambeau Field since 1957. They have the most wins of any NFL franchise. The Packers are the last of the "small town teams" which were common in the NFL during the league's early days of the 1920s and 1930s. Founded in 1919 by Curly Lambeau, Earl "Curly" Lambeau and George Whitney Calhoun, the franchise traces its lineage to other semi-professional teams in Green Bay dating back to 1896. Between 1919 and 1920, the Packers competed a ...
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Chevrolet Corvette
The Chevrolet Corvette is a two-door, two-passenger luxury sports car manufactured and marketed by Chevrolet since 1953. With eight design generations, noted sequentially from C1 to C8, the Corvette is noted for its performance and distinctive fiberglass or composite panels. It was front-engined through 2019 and mid-engined since. The Corvette is currently the only two-seat sports car produced by a major United States auto manufacturer and it serves as Chevrolet's halo vehicle. In 1953, GM executives accepted a suggestion by Myron Scott, then the assistant director of the Public Relations department, to name the company's new sports car after the corvette, a small maneuverable warship. The first model, a convertible, was introduced at the 1953 GM Motorama as a concept car; production models went on sale later that year. In 1963, the second generation was introduced in coupe and convertible styles. Originally manufactured in Flint, Michigan, and St. Louis, Missouri, the C ...
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National Football League
The National Football League (NFL) is a professional American football league that consists of 32 teams, divided equally between the American Football Conference (AFC) and the National Football Conference (NFC). The NFL is one of the major professional sports leagues in the United States and Canada and the highest professional level of American football in the world. Each NFL season begins with a three-week preseason in August, followed by the 18-week regular season which runs from early September to early January, with each team playing 17 games and having one bye week In sport, a bye is the preferential status of a player or team that is automatically advanced to the next round of a tournament, without having to play an opponent in an early round. In knockout (elimination) tournaments they can be granted eit .... Following the conclusion of the regular season, seven teams from each conference (four division winners and three wild card teams) advance to the p ...
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NFL Championship Game, 1961
The 1961 NFL Championship Game was the 29th title game. It was played on December 31 at "New" City Stadium, later known as Lambeau Field, in Green Bay, Wisconsin, with an attendance of 39,029. The game was a match-up of the Eastern Conference champion New York Giants (10–3–1) and the Western Conference champion Green Bay Packers (11–3). The home team Packers were a -point favorite. Packers Ray Nitschke, Boyd Dowler, and Paul Hornung, were on leave from the U.S. Army. Hornung scored 19 points (a touchdown, three field goals, and four extra points) for the Packers and was named the MVP of the game, and awarded a 1962 Chevrolet Corvette from ''Sport'' magazine. The victory was the first of five NFL titles won in a seven-season span by the Packers and their head coach, Vince Lombardi. It was the Packers' seventh league title and their first in 17 years. Overview This was the first NFL championship game held in Green Bay. The Packers' only other championship home game unt ...
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Green Bay, Wisconsin
Green Bay is a city in the U.S. state of Wisconsin. The county seat of Brown County, it is at the head of Green Bay (known locally as "the bay of Green Bay"), a sub-basin of Lake Michigan, at the mouth of the Fox River. It is above sea level and north of Milwaukee. As of the 2020 Census, Green Bay had a population of 107,395, making it the third-largest in the state of Wisconsin, after Milwaukee and Madison, and the third-largest city on Lake Michigan, after Chicago and Milwaukee. Green Bay is the principal city of the Green Bay Metropolitan Statistical Area, which covers Brown, Kewaunee, and Oconto counties. Green Bay is well known for being the home city of the National Football League (NFL)'s Green Bay Packers. History Samuel de Champlain, the founder of New France, commissioned Jean Nicolet to form a peaceful alliance with Native Americans in the western areas, whose unrest interfered with French fur trade, and to search for a shorter trade route to China throu ...
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New York City
New York, often called New York City or NYC, is the List of United States cities by population, most populous city in the United States. With a 2020 population of 8,804,190 distributed over , New York City is also the List of United States cities by population density, most densely populated major city in the United States, and is more than twice as populous as second-place Los Angeles. New York City lies at the southern tip of New York (state), New York State, and constitutes the geographical and demographic center of both the Northeast megalopolis and the New York metropolitan area, the largest metropolitan area in the world by urban area, urban landmass. With over 20.1 million people in its metropolitan statistical area and 23.5 million in its combined statistical area as of 2020, New York is one of the world's most populous Megacity, megacities, and over 58 million people live within of the city. New York City is a global city, global Culture of New ...
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