You cannot do this anymore. Paypal requires that the tracking number have a confirmed delivery before you can withdraw the funds. They are marked in your balance and they will be cleared once the item is delivered. It is a bit annoying.
I found the information when PayPal holds the fund;
You have been an eBay member for less than 6 months, and you sell an item for more than $100
You have an eBay feedback score of less than 100, and you sell an item for more than $100
You have a buyer dissatisfaction percentage* greater than 5%
You have an average Detailed Seller Rating of less than 4.5 (Buyer can leave detailed seller ratings right after the transaction, or at a later time, up to 60 days after the transaction)
You have received fewer than 20 Detailed Seller Ratings in the last 12 months
You are listing your item in a high-risk category such as gift certificates, video games, cell phones

, computers, or consumer electronics.
PayPal will not hold the fund if;
You have been an eBay member for 6-months or more, and
Your total Feedback score is 100 or greater, and
Your Buyer dissatisfaction percentage** is less than 5%.
Or
Your average DSR is 4.5 or greater and
Your have received 20 or more DSRs in the last 12-months
Your buyer dissatisfaction percentage is less than 5%
I belong to holding category
