 The court stated that for income to be constructively received, the funds must be made available to the taxpayer without substantial limitations.At issue was whether or not a taxpayer faced such substantial limitations when a check was available to her at the post office on the last day of the tax year after the mail carrier attempted to deliver the certified letter containing it to her home earlier the same day.The taxpayer was not at home when the first delivery attempt was made and the carrier left a note that the letter would be at the post office for her.