Some property is of dual character, being part marital and part separate. Numerous cases have addressed these distinctions and should be consulted for specific details beyond the scope of this book.
Briefly stated, dual classification occurs in a number of situations, e.g., where earnings and a non-owning spouse’s efforts during the marriage are applied to separate property; where separate property is improved through addition or accession to it of other property acquired during the marriage; where the efforts of a spouse in actively managing separate property during the marriage augment the value of the property such that the resulting increase should equitably be viewed as marital property.
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