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Cases of Interest: Florida
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Agreements (full category)

FLORIDA: Vitakis-Valchine v. Valchine, No. 4D00-2013 (Fla. Dist. Ct. App. Aug. 22, 2001).
The wife appealed the judgment of dissolution, entered as a result of a mediated settlement. The wife claimed duress and coercion on the part of the husband and the mediator.
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FLORIDA: Kelson v. Kelson, 675 So. 2d 1370 (Fla. 1996).
Voluntary Separation Incentive (VSI) benefits paid to a service member upon voluntary separation from the armed forces qualify as military retirement pay under a property settlement agreement that provides for division of military retirement pay, and federal law does not preclude a state court from enforcing a property settlement that is found to encompass VSI benefits.
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FLORIDA: Cox v. Cox, 659 So. 2d 1051 (Fla. 1995).
The unexecuted portions of a couple's marital settlement agreement are rendered void when the parties remarry or reconcile unless there is a specific statement in the agreement that the parties intended otherwise.
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FLORIDA: Petracca v. Petracca, 706 So. 2d 904 (Fla. Dist. Ct. App. 1998).
An agreement settling marriage dissolution litigation is not subject to a "fair and reasonable" determination by the trial judge.
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Alimony (full category)

FLORIDA: McLean v. McLean, 652 So. 2d 1178 (Fla. DCA 1995).
The wife, who had received more than $1 million in property distribution, should nevertheless be awarded permanent alimony, because she should not be expected to convert a pension plan awarded to her into an income-producing asset.
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Appreciation of Assets (full category)

FLORIDA: Pagano v. Pagano, 665 So. 2d 370 (Fla. DCA 1996).
The appreciated portion of the husband's interest in a family plumbing supply business was marital property, since his marital labor as president and operations manager contributed to the appreciation.
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FLORIDA: Robbie v. Robbie, 654 So. 2d 616 (Fla. DCA 1995).
The appreciation of the husband's interest in a closely held family corporation was marital property even though he was not the key decisionmaker, where he was employed full-time as the general manager and contributed by carrying out the decisions made by others.
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FLORIDA: Webb v. Webb, 636 So. 2d 883 (Fla. DCA 1994).
Appreciation of the husband's separate businesses was marital property, since he worked in the businesses during the marriage.
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Attorneys (full category)

FLORIDA: McAliley v. McAliley, 704 So. 2d 611 (Fla. Dist. Ct. App. 1997).
The wife would be awarded attorney's fees on appeal as a punitive measure for the lawyer/husband's abuse of the judicial system in filing continuous, baseless, and vexatious litigation.
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Attorney's Fees (full category)

FLORIDA: Clinton v. Carver, 675 So. 2d 642 (Fla. DCA 1996).
The husband's parents could not be required to pay attorney's fees to the wife even though they had been joined as parties in the dissolution proceeding and were found to owe money to the wife.
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FLORIDA: Rosasco v. Rosasco, 641 So. 2d 493 (Fla. DCA 1994).
The trial court lacked authority to order the husband to place funds in escrow pending determination of the amount of attorney's fees to be awarded to the wife's attorney.
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FLORIDA: Smallwood v. Perez, 717 So. 2d 154 (Fla. Dist. Ct. App. 1998).
A spouse's motion for attorney's fees from opposing counsel for bad-faith litigation must be made and heard together with the request for attorney's fees from the lawyer's client in the action.
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FLORIDA: Satter v. Satter, 709 So. 2d 617 (Fla. Dist. Ct. App. 1998).
A party seeking to recover fees in a divorce action must show some need for such relief, not just more relative financial strain than the other party.
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FLORIDA: Spano v. Spano, 698 So. 2d 324 (Fla. Dist. Ct. App. 1997).
A spouse who files a motion to set aside a property settlement agreement and judgment may not be awarded attorney's fees under the matrimonial statute permitting fee awards in modification and enforcement proceedings.
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Bankruptcy (full category)

FLORIDA: Adkins v. Adkins, 675 So. 2d 199 (Fla. DCA 1996).
The husband's interest in the wife's profit-sharing plan pursuant to the parties' dissolution judgment was not a debt owed by the wife and therefore was not discharged in her bankruptcy proceeding after the dissolution.
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FLORIDA: Herman v. Herman, 661 So. 2d 1260 (Fla. DCA 1995).
When the husband filed for bankruptcy after the trial court's financial awards, the wife's share of the husband's retirement payments was not subject to the bankruptcy stay, because that share was partly in the nature of support and maintenance.
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Child Support (full category)

FLORIDA: Yockey v. Yockey, No. 4D00-3332 (Fla. Dist. Ct. App. May 16, 2001).
In this case, the father had petitioned to modify the amount of unallocated child support after his oldest child reached the age of majority.
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Classification of Assets (full category)

FLORIDA: Pridgeon v. Pridgeon, 632 So. 2d 257 (Fla. DCA 1994).
Household appliances that wife brought to the marriage must be awarded to her as her nonmarital property.
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FLORIDA: Staman v. Staman, 622 So. 2d 1147 (Fla. DCA 1993).
Accounts receivable from husband's medical practice should have been included in the valuation of marital assets.
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FLORIDA: Smith v. Smith, 655 So. 2d 1267 (Fla. DCA 1995).
Certificates of deposit purchased with the husband's nonmarital funds must be classified as marital property where the husband did not claim before trial that they were nonmarital.
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FLORIDA: Baird v. Baird, 696 So. 2d 844 (Fla. Dist. Ct. App. 1997).
Stock shares acquired by the husband before marriage lost their separate character through commingling and various sales and transfers.
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FLORIDA: White v. White, 705 So. 2d 123 (Fla. Dist. Ct. App. 1998).
The husband's unrebutted testimony that his personal injury settlement was to compensate for future injuries, losses, and damages established that the entire settlement was his separate property.
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FLORIDA: Miner v. Miner, 727 So. 2d 1080 (Fla. Dist. Ct. App. 1999).
The husband's debt for medical expenses incurred after the parties' separation would be a marital obligation if the injury causing the expenses occurred during the marriage.
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FLORIDA: Walker v. Walker, 719 So. 2d 977 (Fla. Dist. Ct. App. 1998).
A settlement received by the husband in his wrongful termination of employment suit was nonmarital property under the "analytic approach," which classifies damages for pain and suffering, loss of future wages, and future medical expenses as separate property.
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FLORIDA: Johnson v. Johnson, 725 So. 2d 1029 (Fla. Dist. Ct. App. 1999).
Debts owed by the husband's nonmarital businesses were nonmarital even though they were personally guaranteed by him during the marriage.
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Closely Held Businesses (full category)

FLORIDA: Johnson v. Johnson, 725 So. 2d 1029 (Fla. Dist. Ct. App. 1999).
Debts owed by the husband's nonmarital businesses were nonmarital even though they were personally guaranteed by him during the marriage.
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FLORIDA: Robbie v. Robbie, 654 So. 2d 616 (Fla. DCA 1995).
The appreciation of the husband's interest in a closely held family corporation was marital property even though he was not the key decisionmaker, where he was employed full-time as the general manager and contributed by carrying out the decisions made by others.
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Closely Held Corporations (full category)

FLORIDA: Schiller v. Schiller, 625 So. 2d 856 (Fla. DCA 1993).
Trial court could not distribute husband's partnership interest to wife; instead, it could impose a charging lien on the partnership interest for a specific dollar amount.
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Corporations (full category)

FLORIDA: Barineau v. Barineau, 662 So. 2d 1008 (Fla. DCA 1995).
Courts are not barred from inquiring whether a nonprofit corporation is the alter ego of a party in a dissolution proceeding for the purpose of achieving equitable distribution.
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Debts (full category)

FLORIDA: Kranz v. Kranz, 737 So. 2d 1198 (Fla. Dist. Ct. App. 1999).
Credit card debt incurred by the wife during voluntary separation but before the filing of the petition for dissolution is not necessarily nonmarital debt, nor is it subject to unequal distribution.
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FLORIDA: Adkins v. Adkins, 675 So. 2d 199 (Fla. DCA 1996).
The husband's interest in the wife's profit-sharing plan pursuant to the parties' dissolution judgment was not a debt owed by the wife and therefore was not discharged in her bankruptcy proceeding after the dissolution.
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FLORIDA: Walton v. Walton, 657 So. 2d 1214 (Fla. DCA 1995).
The parties' contractual obligation to prepay the college tuition of their children was a marital liability which could be assigned as part of their property division.
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FLORIDA: Miner v. Miner, 727 So. 2d 1080 (Fla. Dist. Ct. App. 1999).
The husband's debt for medical expenses incurred after the parties' separation would be a marital obligation if the injury causing the expenses occurred during the marriage.
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FLORIDA: Johnson v. Johnson, 725 So. 2d 1029 (Fla. Dist. Ct. App. 1999).
Debts owed by the husband's nonmarital businesses were nonmarital even though they were personally guaranteed by him during the marriage.
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Disability Benefits (full category)

FLORIDA: Abernethy v. Fishkin, 699 So. 2d 235 (Fla. 1997).
A state court may enforce a final judgment which guarantees a steady monthly payment to a former spouse through an indemnification provision requiring alternative payments to compensate for a reduction in nondisability benefits divided as part of a property settlement agreement.
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Dissipation of Assets (full category)

FLORIDA: Ruiz v. Ruiz, 821 So. 2d 1112 (Fla. Dist. Ct. App. 2002).
The trial court erred by leaving the husband solely responsible for debts arising from his withdrawals from his IRA, where at least part of the debts were used for marital purposes, even though the husband demonstrated a distinct lack of candor with the court throughout the proceedings.
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FLORIDA: Stock v. Stock, 693 So. 2d 1080 (Fla. Dist. Ct. App. 1997).
The wife's transfer of real property to her mother did not involve intentional misconduct so as to constitute dissipation of a marital asset.
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FLORIDA: Siravo v. Siravo, 693 So. 2d 676 (Fla. Dist. Ct. App. 1997).
The husband's dissipation of his business and its inventory did not justify stripping him of a proportionate share of the parties' marital assets, where the trial court dealt with his misconduct by awarding alimony based on imputed income and could impose other sanctions.
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FLORIDA: Segall v. Segall, 708 So. 2d 983 (Fla. Dist. Ct. App. 1998).
Expenditures by the husband before any irreconcilable breakdown in the parties' marriage could not be considered dissipation of marital assets so as to justify an unequal distribution.
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Division of Property (full category)

FLORIDA: Maddox v. Maddox, 750 So. 2d 693 (Fla. Dist. Ct. App. 2000).
The husband's gift of real property to the wife was a marital asset subject to equitable distribution.
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FLORIDA: Kranz v. Kranz, 737 So. 2d 1198 (Fla. Dist. Ct. App. 1999).
Credit card debt incurred by the wife during voluntary separation but before the filing of the petition for dissolution is not necessarily nonmarital debt, nor is it subject to unequal distribution.
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FLORIDA: Pridgeon v. Pridgeon, 632 So. 2d 257 (Fla. DCA 1994).
Household appliances that wife brought to the marriage must be awarded to her as her nonmarital property.
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FLORIDA: Schiller v. Schiller, 625 So. 2d 856 (Fla. DCA 1993).
Trial court could not distribute husband's partnership interest to wife; instead, it could impose a charging lien on the partnership interest for a specific dollar amount.
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FLORIDA: McAvoy v. McAvoy, 662 So. 2d 744 (Fla. DCA 1995).
A payment schedule was necessary to enable the wife to enforce her lump-sum equitable distribution award.
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FLORIDA: Chabotte v. Chabotte, 707 So. 2d 923 (Fla. Dist. Ct. App. 1998).
The trial court in a dissolution proceeding may not abdicate its statutory duty to distribute property by simplying ordering an equal division and directing the parties to accomplish that division by agreement of binding mediation.
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Double Dipping (full category)

FLORIDA: Bain v. Bain, 687 So. 2d 79 (Fla. Dist. Ct. App. 1997).
Where the husband's pension had been awarded to him as equitable distribution, the trial court erred in considering the pension as a source from which alimony should be paid, except for the amount of payments attributable to postdissolution contributions.
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Employee Benefits (full category)

FLORIDA: Walker v. Walker, 719 So. 2d 977 (Fla. Dist. Ct. App. 1998).
A settlement received by the husband in his wrongful termination of employment suit was nonmarital property under the "analytic approach," which classifies damages for pain and suffering, loss of future wages, and future medical expenses as separate property.
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Expert Witnesses (full category)

FLORIDA: Catalano v. Catalano, No. 2D00-4053 (Fla. Dist. Ct. App. Aug. 3, 2001).
The issue in this case was whether the wife was entitled to a $4,000 fee charged by the accountant the wife hired to examine financial documents the husband produced in support of his motion for change in child custody and reduction in child support.
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Factors in Award (full category)

FLORIDA: Shoffner v. Shoffner, 744 So. 2d 1157 (Fla. Dist. Ct. App. 1999).
The trial court failed to make the required findings of fact to support the award of either alimony or equitable distribution; therefore, the judgment had to be reversed and remanded for findings.
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FLORIDA: Bell v. Bell, 642 So. 2d 1173 (Fla. DCA 1994).
The disproportionate award of marital assets to the wife could not be justified by the husband's incarceration for child molestation, nor could it be supported on the ground that he allegedly would be unable to manage his property while imprisoned.
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FLORIDA: Williams v. Williams, 686 So. 2d 805 (Fla. Dist. Ct. App. 1997).
Neither the nine-year length of the parties' marriage nor the husband's contribution of income and substantial premarital assets justified an unequal division of marital assets in his favor.
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FLORIDA: Horne v. Horne, 711 So. 2d 1310 (Fla. Dist. Ct. App. 1998).
Neither the wife's frugality nor the husband's decision to seek a dissolution without attempting marriage counseling was a legally sufficient basis for an unequal division of their marital property.
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Federal Preemption (full category)

FLORIDA: Kelson v. Kelson, 675 So. 2d 1370 (Fla. 1996).
Voluntary Separation Incentive (VSI) benefits paid to a service member upon voluntary separation from the armed forces qualify as military retirement pay under a property settlement agreement that provides for division of military retirement pay, and federal law does not preclude a state court from enforcing a property settlement that is found to encompass VSI benefits.
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Findings (full category)

FLORIDA: Harreld v. Harreld, 682 So. 2d 635 (Fla. Dist. Ct. App. 1996).
Trial courts must make specific findings about the identity and value of all significant marital assets and liabilities, and must make specific findings that detail their reasons for distributing marital assets unequally.
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Goodwill (full category)

FLORIDA: Weinstock v. Weinstock, 634 So. 2d 775 (Fla. DCA 1994).
Inclusion of good will as a marital asset was improper because the evidence failed to establish a value for the good will apart from the husband's continued presence.
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Income (full category)

FLORIDA: Steiner v. Steiner, 746 So. 2d 1149 (Fla. Dist. Ct. App. 1999).
Rental income generated from the husband's nonmarital real estate was marital property, a bank account in the name of the husband and his mother was marital property, and the principal mortgage reductions paid out of the marital account became marital property.
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Inherited Property (full category)

FLORIDA: Farrior v. Farrior, 736 So. 2d 1177 (Fla 1999).
The wife did not convert her separate assets into marital property merely by pledging them as collateral for the couple's joint debt.
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Joinder (full category)

FLORIDA: Snedaker v. Snedaker, 660 So. 2d 1070 (Fla. DCA 1995).
The wife's battery claim could be pleaded as a separate count in the parties' dissolution action.
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Marital Home (full category)

FLORIDA: Williams v. Williams, 766 So. 2d 1127 (Fla. Dist. Ct. App. 2000).
The temporary award of the marital home to the wife was an abuse of discretion.
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FLORIDA: Bryan v. Bryan, 765 So. 2d 829 (Fla. Dist. Ct. App. 2000).
The wife was not entitled to a greater interest in the marital home based on her contribution of nonmarital assets, since the trial court found no special equity arising from the nonmarital contributions.
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FLORIDA: Gallinar v. Gallinar, 763 So. 2d 447 (Fla. Dist. Ct. App. 2000).
Was the husband entitled to a special equity in the marital home, given his contribution of premarital assets for the down payment?
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FLORIDA: Collins v. Collins, 737 So. 2d 1204 (Fla. Dist. Ct. App. 1999).
The wife's father lent money to the couple for a down payment on the marital home, yet this did not create a special equity for the wife in the home.
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FLORIDA: Todd v. Todd, 734 So. 2d 537 (Fla. Dist. C App. 1999).
The trial court awarded the husband exclusive use of the marital home without providing that the possession would terminate upon remarriage. The court of appeal held that this was error.
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FLORIDA: Hosack v. Hosack, 679 So. 2d 852 (Fla. DCA 1996).
The trial court erred by guaranteeing the husband a minimum amount from the sale of the marital home without regard to the amount of the actual sale price.
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Military Benefits (full category)

FLORIDA: Anciaux v. Anciaux, 666 So. 2d 577 (Fla. DCA 1996).
The husband's military retirement plan was a marital asset subject to distribution even though the spouses were not married for at least 10 years while the husband was a member of the federal uniformed services.
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FLORIDA: Kelson v. Kelson, 675 So. 2d 1370 (Fla. 1996).
Voluntary Separation Incentive (VSI) benefits paid to a service member upon voluntary separation from the armed forces qualify as military retirement pay under a property settlement agreement that provides for division of military retirement pay, and federal law does not preclude a state court from enforcing a property settlement that is found to encompass VSI benefits.
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FLORIDA: Abernethy v. Fishkin, 699 So. 2d 235 (Fla. 1997).
A state court may enforce a final judgment which guarantees a steady monthly payment to a former spouse through an indemnification provision requiring alternative payments to compensate for a reduction in nondisability benefits divided as part of a property settlement agreement.
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Pensions (full category)

FLORIDA: Williams v. Williams, 766 So. 2d 1127 (Fla. Dist. Ct. App. 2000).
The temporary award of the marital home to the wife was an abuse of discretion.
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FLORIDA: Bain v. Bain, 687 So. 2d 79 (Fla. Dist. Ct. App. 1997).
Where the husband's pension had been awarded to him as equitable distribution, the trial court erred in considering the pension as a source from which alimony should be paid, except for the amount of payments attributable to postdissolution contributions.
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FLORIDA: Beasley v. Beasley, 717 So. 2d 208 (Fla. Dist. Ct. App. 1998).
When dividing the husband's pension at the end of the parties' second marriage to each other, the trial court had discretion to include both marriages in its computation of the wife's share of the pension.
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FLORIDA: Boyett v. Boyett, 703 So. 2d 451 (Fla. 1997).
The valuation of a vested retirement plan must not include any contributions made after the judgment of dissolution.
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Personal Injury Awards (full category)

FLORIDA: White v. White, 705 So. 2d 123 (Fla. Dist. Ct. App. 1998).
The husband's unrebutted testimony that his personal injury settlement was to compensate for future injuries, losses, and damages established that the entire settlement was his separate property.
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FLORIDA: Spano v. Spano, 698 So. 2d 324 (Fla. Dist. Ct. App. 1997).
A spouse who files a motion to set aside a property settlement agreement and judgment may not be awarded attorney's fees under the matrimonial statute permitting fee awards in modification and enforcement proceedings.
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FLORIDA: Ritter v. Ritter, 690 So. 2d 1372 (Fla. Dist. Ct. App. 1997).
The trial court erred in precluding the husband from calling the wife's personal injury lawyer to testify concerning her offer to settle her pending personal injury lawsuit.
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Pets (full category)

FLORIDA: Bennett v. Bennett, ___ So. 2d ___, 20 Fla. L. Weekly D225 (Fla. DCA 1994).
Family pets are personal property to be dealt with through the equitable distribution process, rather than through orders for custody and visitation.
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Pre Marital (full category)

FLORIDA: Anson v. Anson, 772 So. 2d 52 (Fla. Dist. Ct. App. 2000).
Was the husband's capital stock a marital asset, and was a retained earnings bookkeeping method the correct method to determine this?
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Professional Practices (full category)

FLORIDA: Williams v. Williams, 683 So. 2d 1119 (Fla. Dist. Ct. App. 1996).
The trial court did not abuse its discretion when it reduced the value of the husband's stock in his law firm by 20% because he held only a minority interest in the firm and the stock was not readily marketable.
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FLORIDA: Weinstock v. Weinstock, 634 So. 2d 775 (Fla. DCA 1994).
Inclusion of good will as a marital asset was improper because the evidence failed to establish a value for the good will apart from the husband's continued presence.
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FLORIDA: Staman v. Staman, 622 So. 2d 1147 (Fla. DCA 1993).
Accounts receivable from husband's medical practice should have been included in the valuation of marital assets.
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Pre Marital (full category)

FLORIDA: Anson v. Anson, 772 So. 2d 52 (Fla. Dist. Ct. App. 2000).
Was the husband's capital stock a marital asset, and was a retained earnings bookkeeping method the correct method to determine this?
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Remarriage (full category)

FLORIDA: Beasley v. Beasley, 717 So. 2d 208 (Fla. Dist. Ct. App. 1998).
When dividing the husband's pension at the end of the parties' second marriage to each other, the trial court had discretion to include both marriages in its computation of the wife's share of the pension.
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Social Security Benefits (full category)

FLORIDA: Johnson v. Johnson, 726 So. 2d 393 (Fla. Dist. Ct. App. 1999).
The husband's Social Security replacement plan was a marital asset with no offset for the wife's future Social Security benefits. The husband in this case was a police officer, while the wife worked as a licensed practical nurse.
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Stocks and Securities (full category)

FLORIDA: Nelson v. Nelson, No. 5D99-826 (Fla. Dist. Ct. App. June 29, 2001).
The husband graduated from high school, but the wife did not complete high school. The husband was 65 years old at the time of the dissolution; the wife was 61. The wife had suffered various health problems, but at the time of the dissolution was healthy. The husband was in good health with no plans for retirement.
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Tax Consequences (full category)

FLORIDA: Vaccaro v. Vaccaro, 677 So. 2d 918 (Fla. Dist. Ct. App. 1996).
A party who seeks consideration of tax consequences should present the tax consequences for all of the tax-burdened assets, not just for a single asset.
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FLORIDA: Livingston v. Livingston, 633 So. 2d 1162 (Fla. DCA 1994).
The trial court erred in calculating the amount of a tax surcharge which the husband owed to the marital estate for federal income taxes it paid on the husband's separate investment income during the marriage.
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FLORIDA: England v. England, 626 So. 2d 330 (Fla. DCA 1993).
Evidence did not support the trial court's decision to consider potential capital gains taxes in determining the value of the business awarded to the husband.
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Third Parties (full category)

FLORIDA: Clinton v. Carver, 675 So. 2d 642 (Fla. DCA 1996).
The husband's parents could not be required to pay attorney's fees to the wife even though they had been joined as parties in the dissolution proceeding and were found to owe money to the wife.
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FLORIDA: Stock v. Stock, 693 So. 2d 1080 (Fla. Dist. Ct. App. 1997).
The wife's transfer of real property to her mother did not involve intentional misconduct so as to constitute dissipation of a marital asset.
Read More About This Case

FLORIDA: Siravo v. Siravo, 693 So. 2d 676 (Fla. Dist. Ct. App. 1997).
The husband's dissipation of his business and its inventory did not justify stripping him of a proportionate share of the parties' marital assets, where the trial court dealt with his misconduct by awarding alimony based on imputed income and could impose other sanctions.
Read More About This Case

Torts (full category)

FLORIDA: White v. White, 705 So. 2d 123 (Fla. Dist. Ct. App. 1998).
The husband's unrebutted testimony that his personal injury settlement was to compensate for future injuries, losses, and damages established that the entire settlement was his separate property.
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Transmutation of Property (full category)

FLORIDA: Farrior v. Farrior, 736 So. 2d 1177 (Fla 1999).
The wife did not convert her separate assets into marital property merely by pledging them as collateral for the couple's joint debt.
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FLORIDA: Farrior v. Farrior, 712 So. 2d 1154 (Fla. Dist. Ct. App. 1998).
Stock which the wife inherited from her family and retained in her name did not become a marital asset either through general conversations between the husband and wife, through the parties' allegedly equal access to the stock, through the parties' use of the stock to enrich their standard of living, or through the pledge of the stock as collateral for marital debts.
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Valuation of Property (full category)

FLORIDA: Nelson v. Nelson, No. 5D99-826 (Fla. Dist. Ct. App. June 29, 2001).
The wife argued that the trial court erred in not granting her a perfected security interest in the stock of a family corporation. The couple here had a long-term marriage: 38 years.
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FLORIDA: Weinstock v. Weinstock, 634 So. 2d 775 (Fla. DCA 1994).
Inclusion of good will as a marital asset was improper because the evidence failed to establish a value for the good will apart from the husband's continued presence.
Read More About This Case

FLORIDA: Ritter v. Ritter, 690 So. 2d 1372 (Fla. Dist. Ct. App. 1997).
The trial court erred in precluding the husband from calling the wife's personal injury lawyer to testify concerning her offer to settle her pending personal injury lawsuit.
Read More About This Case

FLORIDA: Williams v. Williams, 683 So. 2d 1119 (Fla. Dist. Ct. App. 1996).
The trial court did not abuse its discretion when it reduced the value of the husband's stock in his law firm by 20% because he held only a minority interest in the firm and the stock was not readily marketable.
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