FACTS: Adrian, a salesperson who represents several wholesale companies, receives a commission income check worth of $10,000 from Ace Distributors on January 2, 2014. However, the check is dated on December 30, 2013. Adrian argues that she has not gained full control over her check in 2013 because it is unreasonable to her to drive 50 miles to collect the check from the Ace offices. In addition, even though Adrian can collect the check by any means necessary on December 30, 2013, she cannot deposit this check into her account since banks would have closed when she returned. ISSUES: Does Adrian have constructive receipt of the income in 2013? FINDINGS: By applying the doctrine of constructive receipt of the income to the Adrian’s case, we determine that Adrian has a limited control over her check since she cannot deposit the check on December 30, 2013 because the banks are closed. For this reason, Adrian can report the commission income in 2014. REASONING AND AUTHORITY: According to the Regulation §1.451-2(a), under the general rule of the constructive receipt of income, “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 subject to substantial limitations or restrictions”. In this case, we need to determine whether Adrian’s control of the income’s receipt is subject to substantial limitations or restrictions. By looking at the facts that are stated by Adrian, there are two limitations that make her cannot deposit the check and report it in 2013 taxable