-38-                                          
          decedent had not relinquished complete dominion and control over            
          the funds before her death, the checks were not completed gifts.            
          Burnett v. Guggenheim, 288 U.S. at 286 (a gift is not consummate            
          until put beyond recall); sec. 25.2511-1(g)(1), Gift Tax Regs.              
               Moreover, there were insufficient funds in decedent's                  
          account to cover the checks when they were written and when she             
          died.  She could not have intended to relinquish control until              
          the borrowed funds were deposited in her account.  See also                 
          Estate of Dillingham v. Commissioner, 88 T.C. 1569, 1576 (1987)             
          (checks not cashed until 35 days after delivery to donees,                  
          without explanation of the reason for the delay, casts doubt as             
          to whether the checks were unconditionally delivered, or whether            
          decedent had sufficient funds to cover the checks at the time               
          they were delivered), affd. 903 F.2d 760 (10th Cir. 1990).                  
               Despite our holding that decedent retained control over the            
          checks, petitioner may still prevail if we agree that payment of            
          the replacement checks relates back to the delivery of the                  
          original checks.                                                            
               In Estate of Gagliardi v. Commissioner, 89 T.C. 1207 (1987),           
          we addressed the question of whether the relation-back doctrine             
          should apply to checks that were not cashed until after the                 
          donor's death.  Id. at 1211.  Assuming the date of payment of the           
          checks related back to the date the checks were issued (prior to            
          the donor's death), the amount of the checks would be excluded              
          from the donor's Federal gross estate.                                      
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