In Osborn v. Byrne, 43 Conn. 155, 160 (1875), an individual made a deposit to a bank, "not for the ordinary purposes of a deposit, but for the purpose, and with the intention, of applying the same in payment of her indebtedness to the bank to that amount." Articulating reasoning that resembles today's doctrine, the court stated: "If the officers of the bank knew for what purpose the deposit was made, although the amount has never been in fact applied in cancellation of so much of her indebtedness to the bank, we think she should be allowed to set off the amount." Id.