Brown v Brown (1993) 31 NSWLR 582 Facts: In 1958 Mrs. Brown bought property with her adult children, two sons and two daughters. She contributed half the purchase price. She was 58 at the time of purchase. Without her knowledge, the property was registered in the names of the sons alone. She lived in the house for thirty years, by the end with one of the sons and his family. In 1987, she discovered she was not on title to the property. The action commenced, and she died several months later. The evidence of all family members was contradictory about what had happened in 1958, and there did not appear to have been any agreement or common understanding re title at the time. Result: The presumption of advancement was found to apply. Traditionally, it had applied to gifts from fathers to children, but not to mothers. Given social/economic conditions changing, it was extended to mothers. BUT, on the facts of the case, the presumption of advancement was rebutted in the circumstances. Mrs. Brown needed a home, and could not be found to intend to gift her main asset, the capital in her previous home, to her sons. As the presumption of advancement was rebutted, the ordinary presumption applied. A resulting trust was found.