A marital dissolution case in Illinois is another instance of a party not offering a competing valuation and then appealing the outcome—to no avail. The husband engaged a business valuation expert to appraise an entity that held two real estate properties. The expert testified that, while he was a business valuation expert, he often valued equity in real estate partnerships, for which he relied on appraisals or other estimates of value. In this case, for one property, he relied on a broker opinion of value and a market analysis from a relevant expert. For the other property, which was newly built, he based the value on the construction costs. The wife did not engage a valuation expert to appraise the properties. The trial court accepted the valuation done by the husband’s expert and the wife appealed. But the appellate court upheld the trial court’s decision, noting that there was “sufficient foundation” for the expert’s determination of value. Plus, the court pointed out (citing a prior case), “where a party does not offer evidence of an asset’s value, the party cannot complain as to the disposition of that asset by the court.”

The case is In re Trapp, 2022 IL App (3d) 210291-U; 2022 Ill. App. Unpub. LEXIS 1914, and a case analysis and full court opinion are available on the BVLaw platform .