"The constructive receipt doctrine is taking on renewed significance as public employers have created new conversion options for 'extended leave,' retirement accounts, health insurance continuation, and the like, some of which have at least a limited 'cash out' option. But even in situations where the cash option is limited or capped, the IRS is clear that the 'constructive receipt' rule will continue to apply. The IRS is currently conducting an initiative focusing on benefits, and accordingly is increasing its scrutiny of public employer PTO and benefit plans."