Rowe v. Rowe
In Rowe v. Rowe 154 Ariz. 616, 618-21, 744 P.2d 717, 719-22 (App. 1987) the Court dealt with the issue of apportioning an increase in both profits and value for a separately owned business.
The trial court concluded that a "fair ratio" to quantify "the overlapping contributions" between community contribution and that attributable to the separate property itself was a three-fourths/one-fourth ratio. Id. at 620, 744 P.2d at 721.
In that case we approved the entire amount of the corporate stock in the sole and separate property to be awarded to the sole and separate property owner. Id. at 619, 744 P.2d at 720.
This resulted in no further award to the community with regard to the sole and separate property. Id. at 620, 744 P.2d at 721.
The reason we found no error in this ruling was "because the community had received, through distribution and pension and profit-plan contributions, more than 75% of the sum of net distributable earnings and (assumed) goodwill." Id.
Accordingly, there was no error in the trial court's conclusion that "the community had been fairly compensated for all of its contributions to the growth of a separate business." Id.