In Milian v. De Leon (1986) 181 Cal.App.3d 1185, a couple who were romantically involved purchased a home as joint tenants. (Id. at p. 1190.) Milian contributed more to the down payment than his girlfriend, Sanchez, and he covered the mortgage payments in exchange for her agreement to make payments on his car. He also paid the majority of property tax and insurance payments on the property. She paid for improvements to the property. (Ibid.) When they stopped dating, a partition action was commenced. The trial court found the parties had a true joint tenancy, and it initially found they were each entitled to credits of one-half the amounts they spent on maintaining and improving the property, resulting in a net credit to Milian. (Id. at p. 1191.) The court changed its mind, however, and in its interlocutory judgment it ordered that the proceeds of sale be divided equally between the parties without any accounting or reimbursement. The court found the parties had "an implied contract . . . to treat their property equally and to divide the same equally." (Id. at p. 1192.) The court ordered the property sold and the net proceeds divided equally between the parties. (Id. at pp. 1192-1193.) The Court of Appeal affirmed the ruling, explaining that "even absent the agreement found by the court, insofar as any disparity in the contributions of the parties to the initial acquisition of the property is concerned, the determination there was a true joint tenancy supports the trial court's determination that there need be no accounting or contribution." (Milian, supra, 181 Cal.App.3d at pp. 1194-1195.) The court rejected the notion that cases pertaining to property ownership by tenants in common, in which accounting and contribution principles do apply, are applicable to a joint tenancy. (Ibid.) The court noted it had not "discovered a single case in which a true joint tenancy was found and yet an accounting and contribution was ordered because of disproportionate contributions by the parties to the original purchase price." (Id. at p. 1195.) The court added: "Though the discovery gives us some discomfort in terms of legal symmetry, it appears to us that once the court in a partition action has determined that a true joint tenancy exists, it may not order reimbursement or contribution on account of differences in the amounts the parties have paid toward the initial acquisition of the property. Of course, if one joint tenant has advanced funds on behalf of the other and there is an agreement between them for reimbursement in the event of sale of the property, that agreement can be enforced by the court. However, by definition joint tenancy ownership means equal ownership citation, and in the absence of an agreement for reimbursement we are unaware of any authority which authorizes reimbursement on account of unequal contribution to the down payment." (Ibid.)