47-1. Gifts. For some time before she died, Merle Zimmerman allowed her good friend, Joan Robertson, to assist her with her financial affairs. Robertson was given access to Zimmerman's funds, through joint bank accounts, and to Zimmerman's safe-deposit box. At one point, Zimmerman gave Robertson a number of municipal bonds to "put ... in safekeeping." Robertson noticed that the bonds had been placed in a series of Manila en- velopes, and each envelope contained a piece of paper on which was written the name of one of Zimmerman's relative. One envelope, which contained bonds with a face value of $22,000, had Robertson's name in it. When Zimmerman died, Robertson distributed the bonds to the people whose names were in the envelopes and retained the bonds in the en- velope with her own name on it. Zimmerman's estate claimed ownership of the bonds. Robertson asserted that Zimmerman had made a gift to her of the bonds. Discuss whether an effective gift had been made. [Robertson v. Estate of Zimmerman, 778 S.W.2d 805 (Mo.App. 1989)]