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THE GREEN BAG

STATUTE OF FRAUDS. " Lord Tenterden's Act in the United States, and an Im portant Omission Therefrom," by W. T. Fox, Central Law Journal (V. bu, p. 344).

for in the gift of the proceeds, and a gift which does not take effect is disregarded. Moreover, "the doctrine has become established that an equitable conversion by will is presumptively coextensive only with the purposes for which the sale is directed, and hence the distinction WILLS. " The Dead Hand," by J. M. Lely has become established between an equitable in the November Law Magazine and Review conversion for the purposes of the will only (V. xxxi, p. 24), is a criticism of some defects and an equitable conversion out and out." in the English law of wills and suggestion of And an unqualified direction to sell is pre remedies. sumed to be only for the purpose expressed in the will. Hence, a conversion out and out WILLS (Equitable Conversion). In the No has meant less than it did before " for while vember Harvard Law Review (V. xix, p. i), such a conversion before Ackroyd v. Smithson Professor Langdell concludes his important caused any portion of the land the produce of treatise on " Equitable Conversion." He deals which was not disposed of, to go to the testa chiefly with the changes in the law real and tor's personal representative, it now has merely supposed, since the decision of Ackroyd v. the effect of causing the heir to take the same Smithson. On the whole he finds these to be as money." The authorities, however, give less than has generally been supposed. What no satisfactory reason for these changes. It constitutes such conversion is still the de has been held that these changes should be clared intentidn of the testator. Before that extended by analogy to the equitable conver case, evidence of such intention seems to have sion by will of money into land. been looked for only in such directions as the will contained respecting a sale of the land and WITNESSES. " Memoranda to Refresh the mode of dealing with the proceeds inde Mind of Witness and as Substitute for Wit pendent of any gift of the latter. Since that ness's Recollection," by John D. Lindsay, case, such evidence has been primarily looked Bench and Bar (V. iii, p. 12).