Kronforst v. Kronforst
It was error for court to consider profit sharing plan as part of marital estate and also as income in determining amount of alimony.
Johnson v. Johnson
Profit sharing trust cannot be both asset for division and income in awarding alimony.
In Re Marriage of Steinke v. Steinke
Value of interest in retirement plan must be included in the division of property. Where pension is in pay-out status, least speculative means of valuation is to fix percentage of each pension payment.
In Re Marriage of Kennedy v. Kennedy
Where wife receives immediate payout from pension pursuant to a QDRO, the distributions are part of her share of the estate and not income to her in determining maintenance.