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Carol Shay conveyed four of the six parcels of real property she owned to four separate purchasers, all by land sale contracts. She later died intestate, survived by her husband (P) and her sister (D). P petitioned for partition of the two parcels of land which were not under contract. In her answer, D claimed that the parcels which were under contract should also be included in the partition. She argued that she had a one-half interest in all of the land since the doctrine of equitable conversion did not apply to long-term land sale contracts until both parties to the contract have performed all acts necessary to complete it.

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