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Cases of Interest: Source of Funds
National Legal Research Group, Inc.

MINNESOTA: Robert v. Zygmunt, 652 N.W.2d 537 (Minn. Ct. App. 2002).
The wife did not contribute to the retained earnings of a Subchapter S corporation merely (1) by being taxed upon corporate income, where there was no showing that marital funds were used to pay the taxes; and (2) by being physically present at board meetings and casting nominal votes on corporate issues, where other persons clearly made all of the key managerial decisions.
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MISSOURI: Alexander v. Alexander, 956 S.W.2d 957 (Mo. Ct. App. 1997).
The trial court's findings were not sufficiently specific to properly apply the "source of funds" formula to classify the increase in value of the marital home.
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VIRGINIA: Hart v. Hart, 27 Va. App. 46, 497 S.E.2d 496 (1998).
Marital and nonmarital components of hybrid property may be apportioned in the same percentages as their respective contributions to the total equity in the property. The value of improvements, not their cost, should be considered when determining contributions.
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