Question: Read Hornung v. Commissioner, 47 T.C. 428 (1967), which involves the constructive receipt doctrine and how it was used to determine the year of inclusion

Read Hornung v. Commissioner, 47 T.C. 428 (1967), which involves the constructive receipt doctrine and how it was used to determine the year of inclusion in taxable income. How does the constructive receipt doctrine impact a cash-basis individuals taxable income? What factors could have resulted in a different determination?

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