This section is from the book "The Law Of Contracts", by William Herbert Page. Also available from Amazon: Commercial Contracts: A Practical Guide to Deals, Contracts, Agreements and Promises.
A statement as to value, as distinguished from price, is very generally held to be a mere expression of opinion. As between persons in confidential relations, however, an expression of opinion as to value may, if intended to deceive, amount to constructive fraud. A statement of value made by an attorney to his client may amount to fraud; as a false statement by an attorney to an ignorant client as to the value of his inheritance, the probable amount of attorney's fees and the retention of all the other attorneys in town by the opposite party.1 A statement of value made to a vendee by one whom the vendee believes to be his agent, but who is really the vendor's agent, may amount to fraud.2
Representations as to value do not constitute fraud though made between parties whose relation is such as to be usually classed as one of trust and confidence, if no confidence is in fact reposed. So a contract between persons about to inter-marry, in which the woman did not rely on the representations of her prospective husband but on the advice and judgment of her son, is not subject to the ordinary rules of confidential relations.3