In Re Marriage of Brandt v. Brandt


145 Wis. 2d 394, 421-23, 427 N.W.2d 126 (WI Ct. App., 1988)


Four and one-half year period between date of divorce and court’s final decision does not constitute the special circumstances warranting deviation from usual rule that assets are valued as of date of divorce. The “special circumstances” rule applies to conditions over which the parties have little or no control. Here a party’s own conduct contributed to the delay.

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