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the District of New Jersey held that, for purposes of the annual
gift tax exclusion, gifts became complete upon payment of checks
by the bank and related back to the time of their delivery to the
donee. In that case the court relied on Estate of Belcher v.
Commissioner, 83 T.C. 227, 235 (1984), and Estate of Spiegel v.
Commissioner, 12 T.C. 524, 529 (1949), in which we held that the
relation-back doctrine applies to charitable gifts. As a result,
a charitable gift paid by check relates back to the time (i.e.,
is deemed to be made when) the donor delivered the check to the
donee. In Estate of Newman v. Commissioner, supra at 87, we
distinguished those cases on grounds that those cases involved
gifts to charitable donees and annual gift tax exclusions rather
than whether the funds are includable in the donor’s gross
estate. Charitable gifts differ from noncharitable gifts in that
charitable gifts are deductible for income tax purposes. We have
not extended the relation-back doctrine for estate tax purposes
to noncharitable gifts made by check which were unpaid when the
donor died. See id. This result avoids the possibility that
payments deducted for income tax purposes by the donor would be
includable in the donor’s gross estate. See Estate of Newman v.
Commissioner, supra at 88; Estate of Gagliardi v. Commissioner,
89 T.C. 1207, 1212 (1987).
In Estate of Metzger v. Commissioner, supra at 214-215, we
held that, for purposes of section 2503(b), gifts of checks that
were written, delivered, and deposited in the donee's bank
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