In Dundas v. Dundas, the supreme court held that separate analyses can be combined to determine prior earned income for the purposes of determining marital assets.[1] A husband and wife filed for divorce, and, as part of their divorce proceedings, the wife hired a financial expert to testify as to marital assets.[2] Because of the persisting interdependence of the couples’ finances and the still-undetermined legal separation date, the expert prepared two analyses—one for cash flows for the proceeding three years and the other for joint accounts prior to that.[3] The superior court determined the separation date was approximately one year prior to the proceeding but only included the joint account valuation in the equitable distribution.[4] Reversing, the supreme court concluded the superior court had made numerous mistakes regarding identification, valuation, and distribution of marital property, including the failure to include the cash flow analysis.[5] The court reasoned that excluding the entirety of the three-year cash flow was incompatible with the separation date.[6] Reversing the lower court’s decision, the supreme court held that separate analyses can be combined to determine prior earned income for the purposes of determining marital assets.[7]
[1] 362 P.3d 468, 474 (Alaska 2015).
[2] Id. at 472.
[3] Id. at 475.
[4] Id. at 476.
[5] Id. at 474.
[6] Id. at 477.
[7] Id. at 474.
