In Trueheart v. Trueheart, No. 14-02-01256-CV (Tex. App.--Houston 14th Dist. Sept. 23, 2003, no pet.) (mem. op.) (not designated for publication), $ 290,000.00 of community property was awarded to the wife. The court of appeals noted that almost one-half of that consisted of life insurance policies, I.R.A. accounts, and other assets that could not be easily liquidated without significant penalties. The court affirmed an award of spousal maintenance.