1. All of the following are considered "constructive receipt" of income, except:

   1. a) Lori was informed her check for services rendered was available but she did not pick it up.

   2. b) Pierre earned income that was received by his agent. His agent did not deliver the funds to Pierre.

   3. c) Jacque opened a 9-month certificate of deposit in November 2015. It earned $200 interest in 2015. She can withdraw the principal and interest in 2015 if she pays a small penalty ($15).

   4. d) A payment for the purchase of real property placed in escrow. Under the terms of the escrow agreement the payment to seller will only be released at the time a deed is delivered to the buyer. The deed was not delivered to the buyer.