This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
If a broker employed to sell property understates to his principal the price received by him and appropriates the difference, must account to him therefor. Collins v. McClurg, 1 Colo.
App. 348, 29 P. 299; Helberg v. Nickol, 149 I11. App. 249, 37 N. E. 63; Cornwall v. Foord, 96 I11. App. 366; Bassett v. Rogers, 165 Mass. 377, 43 N. E. 180; Stearns v. Hockbrunn, 24 Wash. 206, 64 P. 165; Love v. Hass, 62 Ind. 255; Henshaw v. Wilson, 46 I11. App. 364. And in addition, his fraudulent conduct may subject him to an action for a breach of the contract. Barnard v. Coffin, 141 Mass. 27, 6 N. E. 364. Or to an action of tort. Emmons v. Alvord, 177 Mass. 466, 59 N. E. 126. See also Deceit, Sec. 298.
 
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