Volume 30 — Washington Appellate Reports

<bold>[1] Frauds, Statute of — Vendor and Purchaser — Description of</bold> <bold>Land — Incomplete Description — Reformation — Mutual</bold> <bold>Mistake.</bold> An agreement which expresses the intent of the parties but contains an incomplete legal description of the property affected is not subject to reformation on the basis of a mutual mistake. <bold>[2] Frauds, Statute of — Vendor and Purchaser — Part Performance</bold> <bold>— Factors.</bold> In determining whether sufficient part performance occurred to render enforceable an agreement which does not comply with the statute of frauds, a court will evaluate whether actual and exclusive possession was delivered and assumed, whether<page_number>Page 174</page_number> consideration was paid or tendered, and whether permanent, substantial, and valuable improvements referable to the agreement were made.