unless the recipient can show a gift was intended. The presumptions are, however, easily rebutted. In Fowkes v Pascoe, evidence was shown that a woman had purchased stock in the names of herself and her grandson; evidence by the grandson and granddaughter-in-law that this had been done as a gift was admissible. On the other hand, the presumption is solely concerned with evidence of an intent to create a trust; ulterior motives to create a trust are not taken into account. In Tinsley v Milligan, a woman transferred property to her business partner on trust in order to fraudulently claim social security payments; it was held that this did not defeat the presumption of a resulting trust. The fact that is being proved by the presumption of a resulting trust is the intention to create a trust for the settlor. This view of presumed resulting trusts has been endorsed by Lord Browne-Wilkinson in Westdeutsche Landesbank Girozentrale v Islington LBC [1996] AC 669); "...the presumption of resulting trust is rebutted by evidence of any intention inconsistent with such a trust, not only by evidence of an intention to make a gift." Some have argued that this presumption arises as a result of a lack of intention to transfer any beneficial interest,. This view has generally not received judicial endorsement.(obiter dicta) Voluntary transfer of land Despite the general onus of resulting trust where it is very much on the recipient to show there is intention of a gift, this presumption does not apply in the case of voluntary transfers of land. This is owing to the Law of Property Act 1925 s.60(3), which states: (3) In a voluntary conveyance a resulting trust for the grantor shall not be implied merely by reason that the property is not expressed to be conveyed for the use or benefit of the grantee. Despite that, it was explained in Ali v Khan [2002] EWCA Civ 974 that although LPA abolished the presumption of a resulting trust from the act of the transfer of land alone, it remained open to a court to consider extrinsic evidence to establish that a trust did in fact arise. Automatic resulting trusts In these trusts " there is no mention of any expression of intention in any instrument, or of any presumption of a resulting trust: the resulting trust takes effect by operation of law,(by law:implied that property will revert to