An offer which is not an offer for value and not under seal may be withdrawn at any time before it has been accepted, and can not, after withdrawal, be accepted so as to make a binding contract.1 The right of offeror to revoke is especially clear where notice of revocation is given before the offer is communicated.2 An offer may be withdrawn no matter how far negotiations have progressed, as long as no acceptance has been made,3 or even if money has been paid when the offer was made, if such payment is not, in part, given as consideration for the promise to keep the offer open.4 After the election of a teacher and before his acceptance of such position, the board of education may add further terms to its offer.5 An offer by A to B to guaranty debts which C may incur to B in the future, may be revoked by A before such credit is extended.6 An acceptance by one attorney of an offer by another subject to the approval of the client of such other may be revoked by the first before approval by the client.7

9 Wood v. Pierson, 45 Mich. 313, 7 N. W. 888; Pierson v. March, 82 N. Y. 603; MacFarlane v. Bloch, 59 Or. 1, 115 Ac. 1056; Cummings v. Gann, 52 Pa. St. 484.

10 MacFarlane v. Bloch, 59 Or. 1, 115 Ac. 1056.

1 See Sec. 118 et seq.

2 See Sec. 136 et seq.

3 See Sec. 138 et seq.

1 United States. Moffett, etc., Co. v. Rochester, 178 U. S. 373, 44 L. ed. 1108 [reversing 91 Fed. 28, 33 C. C. A. 319; which reversed 82 Fed. 255]; Minneapolis Threshing Machine Co .v. Evans, 139 Fed. 860.

Alabama. Borst v. Simpson, 90 Ala. 373, 7 So. 814; Sturdivant v. Mt. Dixie Sanitarium, Land & Investment Co., 197 Ala. 280, 72 So. 502.

California. Abbott v. Land, etc., Co. (Cal.), 53 Ac. 445.

Colorado. Smith v. Bateman, 25 Colo. 241, 53 Ac. 457 [affirming 8 Colo. App. 336, 46 Ac. 213; Sherwin v. National, etc., Co., 5 Colo. App. 162, 38 Ac. 392.

Connecticut. Peck v. Edwards, 90 Conn. 669, 98 Atl. 325.

Illinois. Krause v. Kraus, 162 111. 328, 44 N. E. 736; Crandall v. Willig, 166 111. 233, 46 N. E. 755; Corbett v. Cronkhite, 239 III. 9, 87 N. E. 874; People, ex rel., v. Chicago, 278 111. 318, L. R. A. 1917E, 1069, 116 N. E. 158.

Illinois. Augustine v. M. E. Society, 79 111. App. 452; Murray v. Doud, 63 111. App. 247; Young v. Trainor, 57 111. App. 632.

Indiana. Cincinnati, etc., Co. v. Clifford, 113 Tnd. 460, 15 N. E. 524.

Iowa. McCormick, etc., Co. v. Richardson, 89 la. 525, 56 N. W. 682.

Kansas. Nieschburg v. Nothern, 101 Kan. 110, 165 Ac. 857.