Carl
Level 15

Get your taxes done using TurboTax

Would that qualify as "control"?

I would think so. To me, that would be constructive receipt. So I'd include it in 2021 income. You should document this, as it may cause confusion on your 2022 taxes depending on your book keeping methods. You may be confused by a difference that is equal to the amount you had control of on Dec 31, 2021.