Does the term "inference" or "presumption" apply to a joint tenancy deed between husband and wife?

Wife objects to the trial court's use of the term "inference," because Civil Code section 5110 creates instead a "presumption" of community [177 Cal.App.3d 320] property. We find that related case law frequently uses the two terms almost interchangeably to hold that whether evidence is sufficient to overcome a presumption or inference arising from a joint tenancy deed to husband and wife is a question of fact. (See, e.g., In re Marriage of Frapwell (1975) 49 Cal.App.3d 597, 601-602, 122 Cal.Rptr. 718; Price v. Price (1963) 217 Cal.App.2d 1, 10, 31 Cal.Rptr. 350.) Moreover, in the context of the overall statement of findings, it is clear that the trial court believed that husband had rebutted any presumption of community property stemming from the joint tenancy change of title.