Established the precedent of funds withdrawn from an account are presumed to be debits from the funds deposited in a first-in, first-out (FIFO) principle-based fashion. UK’s 1816 case of Devaynes v. Noble. This ruling, however, does not apply to trustees, They are considered to have their own money that is not the trust money, yet available from their own mixed bank accounts, no matter when it was deposited.

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