A taxpayer who had Modified Adjusted Gross Income in excess of the Coverdell Education Savings Account income phase-out limits ($110,000 for single filers and $220,000 if filing a joint return) could gift the cash to another taxpayer (possibly the beneficiary of the Coverdell Education Savings Account) with Modified Adjusted Gross Income less than the income phase-out limits. This taxpayer could then make the maximum contribution of $2,000.