In Carman v. Carman (22 AD3d 1004 [2005]), the Appellate Division, Third Department, held that 20% of defendant's CPA license was marital property where he completed a Bachelor's degree and almost one year of the required two years of practice before the marriage, and during the marriage, finished the remaining practice period, took an exam preparation course and passed all portions of the CPA exam, since the expert's 20% figure represented one sixth of defendant's education and practical experience with a slight increase for exam preparation and successful completion, as the marital portion of defendant's enhanced earning capacity.