Cowden v. Bell
In Cowden v. Bell, 157 Tex. 44, 300 S.W.2d 286 (1957), the Court stated, "There is no sufficient 'fraud' involved unless the parol vendee will suffer an additional and substantial out-of-pocket loss should the vendor be allowed to avoid the contract by invoking the statute." Id. at 290.
Similarly, "the 'fraud' must include an actual loss to the party seeking to avoid the statute" and there must be "circumstances tending to corroborate the testimony as to the actual existence of the contract." Id. at 291.