- 44 -                                         
               With respect to the additional requirement of Ohio law that,           
          in order to pass title, there must be delivery of a properly                
          executed deed, Wayne Bldg. & Loan Co. of Wooster v. Yarborough,             
          supra, on the record before us, we find that that additional                
          requirement was not satisfied on December 31, 1999 (or at any               
          other time in 1999).  We have found that KQC did not deliver the            
          bill of sale to TMC until March 27, 2000.18                                 
               We have found on the record before us that petitioners in              
          each of these cases have failed to carry their burden of estab-             
          lishing that on December 31, 1999 (or at any other time in 1999)            
          KQC made an irrevocable transfer to TMC of legal title to the               
          improved property on Maple Street or to any portion of such                 
          property.  On that record, we further find that petitioners in              
          each of these cases have failed to carry their burden of estab-             
          lishing that all of the essential elements of a bona fide inter             
          vivos gift were present on December 31, 1999 (or at any other               
          time in 1999) with respect to KQC’s claimed noncash charitable              
          contribution to TMC.19                                                      
               18On brief, petitioners acknowledge that TMC did not receive           
          the bill of sale from KQC until Mar. 27, 2000.  We rejected above           
          petitioners’ suggestion that the general warranty deed pertaining           
          to the improved property on Maple Street that Mr. Kaplan executed           
          on behalf of KQC on Mar. 13, 2001, relates back to the bill of              
          sale and thereby effected in 1999 an irrevocable transfer by KQC            
          to TMC of legal title to such property or any portion of such               
          property.  See supra note 16.                                               
               19Consequently, we need not address whether on Dec. 31, 1999           
          (or at any other time in 1999) the remaining essential elements             
                                                             (continued...)           
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