CarFax doesn't really know whether it's been in an accident. Fraud is "a false and material misrepresentation made by one who either knows its falsity or is ignorant of its truth". Carfax is only saying it hasn't been in an accident to the extent of their knowledge, and their knowledge is scant. This is why they were successfully sued for violating the consumer protection laws of all 50 states. Selling a salvage title car is incredible frustrating and difficult. Plan to either a) keep it forever, or 2) part it out.