2002 WI App 25, 250 Wis. 2d 647, 640 N.W.2d 220 (WI Ct. App., 2002)
Trial court erroneously exercised discretion when it included appreciation of a farm in the marital estate based on contributions to marriage as a whole rather than the individual contributions of each party. A finding that the efforts of spouses contributed to appreciation is insufficient. Court must find that one of the spouse’s contribution was a catalyst to the appreciation.
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