Kyle v. Kyle

In Kyle v. Kyle (156 AD2d 508 [1989]), the same court held that defendant's application to reopen the trial for the purpose of taking testimony regarding the value of plaintiff's principal's license and determining the amount, if any, to which defendant was entitled with respect to that license was properly denied. In so holding, the court reasoned that since plaintiff testified at trial that he still needed two courses in order to obtain his principal's license, he never completed the educational requirements for a principal's license and he did not acquire his principal's license during the marriage, his uncompleted course of studies in possible anticipation of obtaining a principal's license in the future did not constitute marital property susceptible to equitable distribution.