Book-entry transfer is insufficient to complete a valid gift of money without available cash balance.

A gift of money cannot be treated as completed merely through book entries where there is no sufficient cash balance for actual delivery of the amount. The Court applied its contemporaneous ruling on the same legal question and held that the book-entry transfer, in these circumstances, did not validly constitute a completed gift. The alleged transfer to the grandchildren therefore failed as an effective gift, and the amount remained includible in the estate.

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Issues: Whether a gift of money could be validly made by book entries in the absence of sufficient cash balance for physical delivery of the amount.

Analysis: The dispute turned on whether the alleged transfer to the grandchildren constituted a completed and effective gift when it was made only by entries in the books of the firm and there was no adequate cash balance for actual cash delivery. The Court followed its contemporaneous decision on the same legal question and treated the book-entry transfer, in these circumstances, as not sufficient to validate the alleged gift.

Conclusion: The gift was not validly completed, and the amount was liable to be included in the estate.

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