Income which is credited to the account of or set apart for a taxpayer and which may be drawn upon by it at any time is subject to tax for the year during which so credited or set apart, although not then actually reduced to possession. To constitute receipt in such a case, the income must be credited or set apart to the taxpayer without any substantial limitation or restriction as to the time or manner of payment or condition upon which payment is to be made, and must be made available to the taxpayer so that it may be drawn upon at any time. The income must be brought within the taxpayer's own control and disposition. A book entry, if made, should indicate an absolute transfer from one account to another. Where a corporation contingently credits its employees with bonus stock, but the stock is not available to such employees until some future date, the mere crediting on the books of the corporation does not constitute receipt.
2.26 Ark. Code R. 51-404(a)(1)