Which one or ones apply here?

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Tax research project The case: A new member of the Phoenix Suns wants the team to transfer $10 million into an escrow account, in his name, for later withdrawal. The player suggests this payment in lieu of the traditional signing bonus. Think about the tax doctrines we discussed in class (for example, economic substance doctrine, business purpose doctrine, etc.). Which one or ones apply here? When is this income taxable to him? Under what conditions can recognition of the income be deferred? Explain and support your answer using the Internal Revenue Code, Treasury Regulations, IRS Rulings, and court cases.

 

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