In re Cohn

Leopold Cohn, entitled to shares held in his family firm's name, gave his wife a note on her birthday declaring five hundred shares of his stock entitlement to be her gift, explaining to family members that he could not deliver the actual certificates that day because they were held in the firm's safe deposit box, but promising to deliver them once able; Cohn died six days later without ever delivering the physical certificates, and the probate court awarded the shares to his wife, prompting an appeal by other family members with estate interests.