Court Rejects Appreciation in Value Calculation, Citing SSVS Violations

BVLaw
Court Case Digests
May 29, 2018

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marital dissolution/divorce
expert testimony, fair market value (FMV), SSVS-1, appreciation, separate property, valuation date, marital property
Hebert v. Cote
Case No. 312017DR000305, Circuit Court of the Nineteenth Judicial Circuit in and for Indian River County Florida (Order 5/29/2018 and Order 8/29/2018)
US
State Court
Florida
Circuit Court
Charles Clay Price (wife); R. James Alerding (husband)
Pegg

Summary

In appreciation in value case, court excludes nonowner spouse’s valuation testimony under Daubert, finding expert’s calculation of “minimum marital component” is not a methodology approved under the applicable SSVS for determining fair market value and also violated other SSVS requirements.

See Also

Hebert v. Cote

Full Text of Court Cases
May 29, 2018

In appreciation in value case, court excludes nonowner spouse’s valuation testimony under Daubert, finding expert’s calculation of “minimum marital component” is not a methodology approved under the applicable SSVS for determining fair market value and also violated other SSVS requirements.