What is the test for establishing that a deed is delivered at a certain date?

"New York", United States of America

The following excerpt is from Schumacher's Estate, In re, 166 N.Y.S.2d 336, 8 Misc.2d 349 (N.Y. Surr. Ct. 1957):

'No other evidence was given than that which the deed itself furnished, for the purpose of showing the time of its delivery; and under the state of the proof, the law presumes it to have been delivered at the time of its date.' (People v. Snyder, 41 N.Y. 397, 402.)

'In the absence of any proof to the contrary, it must be presumed that these deeds were delivered at their date.' (Purdy v. Coar, 109 N.Y. 448, 450, 17 N.E. 352.)

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