In this tax dispute, the appellants challenge the district court’s determination that certain stock proceeds were received in 2006 under the “constructive receipt” doctrine. We have considered the briefs, the record on appeal, arid all relevant law, and we conclude that the district court’s judgment should be affirmed essentially for the reasons articulated in the court’s opinion on summary judgment. We agree with the district court that the appellants have not shown a “substantial limitation” on receipt of the stock proceeds when they first became available in 2006.

AFFIRMED.