Apparently legal thought did not always so roundly condemn the idea of revocable gifts as it does today. There are several early cases indicating that the absence of a power of revocation in any donative transaction involving a substantial amount of property was a suspicious circumstance to be explored by the court and explained by the donee before the gift was given effect. And, indeed, dicta indicating that a person when entering into a gift inter vivos may, if he sees fit, reserve to himself the right to revoke it can also be found in some of the older cases. The significance of these dicta, however, is concededly dwarfed by the number of modern cases containing broad statements about the invalidity of any such gift.
John L. Garvey, Revocable Gifts of Personal Property: A Possible Will Substitute, Part II, 16 CATH U. L. REV. 256 (1967).