trust is where the transfer fails, and there is no reason to assume it was intended as an outright gift. There are several types of relationship where it is automatically presumed to be a gift. Where a father transfers property to a child, it is presumed that the property was an outright gift, as in Bennet v Bennet. There is no similar recognition for a transfer from a mother, something recognised as a gift in Australia. A similar presumption exists where a transfer is made from a husband to a wife, as in Tinker v Tinker. Presumed resulting trusts do arise, however, in one of three situations; where it is a voluntary gift, where there is a contribution to purchase price, and where the presumption that it was an outright gift can be rebutted. Where a gift is voluntary, the assumption for personal property is that it creates a resulting trust on failure, as in Re Vinogradoff. For real property, Section 60(3) of the Law of Property Act 1925 prevents the creation of automatic resulting trusts, but does not comment on presumed trusts. In Hodgson v Marks, it is generally agreed that a presumed resulting trust was created over a transfer of real property, although there is some dispute. Where a person contributed to the price of a piece of property, they are presumed to take an equivalent equitable interest in that property; this is the "clearest form of presumed resulting trust", and was recognised by both Browne-Wilkinson in Westdeutsche Landesbank and Megarry in Vandervell (No. 2). These principles originated with Eyre CB's judgment in Dyer v Dyer, where he said that: Thus, where a person contributes to the purchase of the property, they will receive an equivalent equitable interest in any resulting trust that arises. For trusts over homes, a distinct set of rules have arisen that do not apply to other land, because of the additional concerns. For example, while contributing to the mortgage will create an equitable interest, as in Lloyds Bank v Rosset, contributing to domestic expenses will not, as in Burns v Burns. It must also be demonstrated that the contribution was not made for any purpose other than acquiring an equitable interest; in Sekhon v Alissa, for example, a mother transferred a house into her daughter's name to avoid capital gains tax. The court ruled that this created a resulting trust; because tax avoidance