How have courts dealt with fraud allegations in real estate transactions?

(b) Ikeda v. Curtis, 1953, 43 Wash.2d 449, 261 P.2d 684, was an action for fraud in the sale of hotel property. A fifty-three room hotel was represented as having thirty-four or thirty-five permanent guests. The hotel had been used as a house of assignation or prostitution, and had twelve permanent tenants. The misrepresentation was not as to the amount of the income, but as to its source. The lower court held there had been fraud. Held: "We held in Perkins v. Marsh (supra) that, under certain circumstances, there is a duty to disclose a material fact even where there was no fiduciary relationship * * *.