Minnesota Supreme Court affirms that passive appreciation in nonmarital property is nonmarital

Business Valuation UpdateVol. 9 No. 11
Legal and Court Case Update
November 2003
3444 Sheet Metal Work
332322 Sheet Metal Work Manufacturing
marital dissolution/divorce
discount for lack of marketability (DLOM), marital dissolution, minority interest, s corporation

In re the Marriage of Gottsacker
2003 Minn. LEXIS 405
July 17, 2003
State Court
Court of Appeals
Lyndon Steele, ASA (for wife); Stephen G. Dennis, CPA/ABV (for husband); Stephen T. Broz (for husband)


Earnings retained in wife’s AAA were not income because they might never be distributed, nor were the earnings active appreciation.

See Also

In re the Marriage of Gottsacker

Whether an Accumulated Adjustment Account (AAA) in a subchapter S corporation in which one spouse has a nonmarital interest is marital property depends on the degree of ownership and control ...