When one person pays for real property but title is transferred to another, some courts will create a resulting trust. The Massachusetts Appeals Court defined the doctrine this way:

"A resulting trust is implied when a transfer of property is made to one person and the purchase price is paid by another; in such a case a trust results in favor of the person who furnished the consideration. Such implication is based on the natural presumption that, in the absence of anything to show the contrary, he who supplies the purchase price intends that the property bought shall inure to his own benefit and not that of another, and that the conveyance is taken in the name of another for some incidental reason. A resulting trust must arise, if at all, at the time of the execution of the deed. The statute of limitations for a resulting trust claim is six years, and the claim accrues when the plaintiff becomes aware that the trust has been repudiated. The standard for repudiation is more than nonperformance; repudiation must be open and notorious."

Because this occurred in the case of Sullivan v. Gilson, 2019 Mass App. Unpub. LEXIS 235, 2019 WL 1467205 (Mass. App. Ct. 2019), the court held that the oral promise to convey title to the property to the person who paid for it is enforceable as a resulting trust even though it is not enforceable under the statute of frauds. The resulting trust doctrine is effectively an exception to the requirement that promises to convey land must be in writing.