Different Income Valuations May Be Used to Determine Equitable Distribution and Alimony, Provided They Are Fair and Statutorily Compliant

Business Valuation UpdateVol. 11 No. 9
Legal and Court Case Update
September 2005
3827 Optical Instruments and Lenses
marital dissolution/divorce
income approach, marital dissolution, double counting

Steneken v. Steneken (II)
2005 N.J. LEXIS 578
May 18, 2005
State Court
New Jersey
Supreme Court
Todd M. Sahner
Christopher Sullivan (for wife); Rufino Fernandez (for wife); Linda Schaeffer (for wife); Kenneth Arlein (for husband)


The main issue in this marital dissolution case was whether in setting an award of alimony and in establishing equitable distribution in respect of a closely held corporation, the same income determination must be used.

See Also

Steneken v. Steneken (II)

The question was whether it is impermissible "double counting" to use actual income for alimony purposes but a lower "normalized" income amount when valuing a closely held business for equitable distribution purposes.