Ellis is an executive with a software corporation who received restricted stock from her employer in Year 1. Ellis must surrender the stock to the employer if she terminates her employment for any reason prior to Year 7, at which point the restriction lapses. In Year 2, Ellis promises to convey the stock to her daugh daughter Diane if Diane is accepted to medical school. In Year 4, Diane receives her acceptance letter. A couple weeks later but now in Year 5, Ellis formally assigns the stock certificates. Ellis continues to work for the company through Year 7, when the restrictions on the stock lapse. In what year did Ellis make a gift to Diane? Base your answer on the principles discussed in the chapter, and then compare your answer to the holding of Rev. Rul. 98-21, 1998-1 C.B. 975.