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Max enters into a land sale contract (an agreement where the seller receives monthly payments from the buyer for the sale of land) for the

Max enters into a land sale contract (an agreement where the seller receives monthly payments from the buyer for the sale of land) for the purchase of a parcel of land from Ned. Both Max and Ned had agreed to the terms of the sale. In order for this contract to be enforceable against Max, what must Ned show concerning the form of the contract? What requires this of him?

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