Actual and Constructive Receipt
a.    Code: 446, 451(a)
b.    Reg: 1.466-1(c)(1)(i), 1.451-1(a), 1.451-2
2.    1.451-2(a): constructive receipt occurs when income is credited w/out restriction, set apart, or otherwise made available to the taxpayer.  The regulation establishes items over which they have sufficient control to compel payment even though they may not yet have actually received payment.
3.    1.451-2(a) also provides that constrictive receipt may only arise when there are not substantial limitations or conditions on the taxpayer’s right to bring the funds w/in their control.  See page 287 for example.
4.    In addition to considering whether there are “substantial limitations” or “restrictions” on the right to receive an item, judicial and administrative rulings have limited the application of the doctrine by considering:
a.    the debtor’s ability to pay,
b.    whether the amount of the obligation is fixed or ascertainable, &
c.    whether there are contingencies or limitations on the right to receive the item.