NIMS, Judge:
Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $37,282.72. After a concession by petitioner, the issues for decision are as follows:
(1) Whether $94,960 in decedent's checking account is includable in decedent's gross estate under section 2031,1 where checks totaling this amount had been mailed to charitable donees before decedent's death but did not clear the drawee...