Does the presumption of undue influence apply in marital transactions in which one spouse has deeded property to the other?

The presumption has been "regularly applied in marital transactions in which one spouse has deeded property to the other," and thereby obtained an unfair benefit at the expense of the other, including property transfers like the Quitclaim Deed here that involved no consideration or inadequate consideration. (Burkle, supra, 139 Cal.App.4th at pp. 730-731 [reviewing history of presumption in the case law and holding that the presumption of undue influence applies only to transactions in which one spouse obtains

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an unfair advantage over the other], citing Haines and Weil v. Weil (1951) 37 Cal.2d 770, 787-789.)