In Williamson v. Kinney (1942) 52 Cal. App. 2d 98, a married couple had deeded community property to the wife in an attempt to protect the property from a potential liability of the husband's. ( Id. at p. 101.) The trial court found that the property remained community property, and the Court of Appeal affirmed, noting that there was no testimony expressly showing the intention of the parties as to whether the property should remain community property or become the wife's separate property. ( Id. at p. 102.)