Boyd v. Boyd (2004)
In Boyd v. Boyd, 131 S.W.3d 605, 612 (Tex. App.-Fort Worth 2004, no pet.), the husband sought economic contribution alleging that he used separate funds to reduce the mortgage on a home purchased during the marriage. He testified the money used to reduce the mortgage came from the sale of another house that was his separate property. Id. at 613-14.
In holding the evidence insufficient to rebut the community presumption, the court stated, "the trial court was left to surmise or speculate, based on the husband's testimony alone, that the proceeds from the sale of the husband's separate property were the source of funds that created his claim for economic contribution." Id. at 616-17.