Appreciation of Assets
Subdivision (c)(2) of this section limits required evidence of appreciation of non-marital property to contributions of personal effort.
Fairness required both parties to share equally in appreciation or depreciation of marital residence, subject to a credit to wife for mortgage payments and improvements.
Where appreciation in value of a stock trust was not due to an addition of marital funds, but was due to economic factors, the appreciation was non-marital property.
Evidence which monetized the value of husband’s contribution to the appreciation of farmstead devised to wife during marriage did not warrant his ward of 30% of the appreciation in value of 51 acre portion of farmstead, and remand was thus proper.
The appreciation on stocks acquired during the marriage is marital property.
