In Wyoming, personal goodwill is not part of the marital estate, but it’s likely that some was included in a recent case. The husband owned a business and valued it at $75,000, which was merely the appraised value of the firm’s assets (asset approach). The husband did not provide any testimony of a valuation expert at trial. The wife used an expert (a CPA and CVA) who used the capitalization of earnings approach to come up with a value of $308,000, which notably included all goodwill. Even though the husband argued that the goodwill was all personal goodwill, the court accepted the $308,000 valuation and an appellate court affirmed.

The case is Snyder v. Snyder, 2021 WY 115, and you can read a case analysis and the full opinion on the BVLaw platform.