states have adopted some variation of the Uniform Act, others have arrived at a similar position through the interpretations of their courts. See, e.g., Lucenti v. Cayuga Apartments, 48 N.Y.2d 530, 423 N.Y.S.2d 886, 399 N.E.2d 918, 923-24 (1979); see also Koenders, supra, §§ 6, 7. This court has applied the theory of equitable conversion in limited cireumstances affecting title, see Konecny v. von Gunten, 151 Colo. 376, 379 P.2d 158 (1968)(finding vendors incapable of unilaterally changing their tenancy in common to joint tenancy during the executory period of the contract because their interest had been equitably converted into a mere security interest and the vend-ee's interest into realty), and refused to apply it in some circumstances, see Chain O'Mines, 101 Colo. 231, 72 P.2d 265 (<HOLDING>). It has also characterized the theory as
holding that the presumption of a yeartoyear holdover tenancy applies even if the original lease contained a renewal option if the tenant fails to affirmatively exercise the option holding that under an option requiring renewal at the expiration of the lease but providing no more specific time requirement the lessee had a reasonable time to exercise the option within the term of the lease holding that even if the doctrine applies to option contracts no conversion would take place until the option were exercised by the party having the right of election holding that under an option requiring renewal at the expiration of the lease the lessee was required to exercise the option on or before the last day of the lease holding that a company that sold an option to buy stock while secretly intending never to honor the option violates  10b and rule 10b5