Spence v. Spence

In Spence v. Spence (287 AD2d 447 [2001], lv dismissed 97 NY2d 725 [2002]), the Appellate Division, Second Department found that the husband's enhanced earning capacity as an investment banker was not marital property subject to equitable distribution under circumstances where he earned his MBA, Series 7 license and Series 63 license four years before the marriage, so that his increased earning capacity was not attributable to a professional license or degree acquired during the marriage.