a.    Dad gave the interest coupons but not the bond that they came from.  And Scalia said that “the power to dispose of income is the equivalent of ownership of it.”
b.    Basically, the court imputed the realization on the father even thought the coupon had not matured b/c of the exercise of dominion over the interest in giving it to his son.
c.    remember: you cannot separate the fruit from the tree
d.    you can give the tree away with the fruit and then there would be no taxable GI on the donor and it would be a gift to the donee under 102 and 1015