Salgado and Salgado

When a trial court in a dissolution case relies on a particular valuation methodology, there must be some evidence in the record that sets forth that methodology.

Husband appealed the trial court's dissolution judgment. During dissolution proceedings, the trial court valued the family business at $600,000 awarding the business to the husband and awarded an equalizing judgment to the wife for half that amount. At trial, Husband testified that the business was worth only as much as the assets, because the business is highly dependent on bidding. Wife testified that the business was worth $600,000. She came to this figure based on simple Internet searches and a "multiplication of earnings" valuation. On appeal, Husband argued that Wife's testimony was entirely guesswork and lacked supporting evidence. The Court found that when a trial court in a dissolution case relies on a particular valuation methodology, there must be some evidence in the record that sets forth that methodology. The Court held that under the circumstances, when neither party's valuation can be credited on appeal, the case must be remanded for the trial court to consider the question of value. Judgment reversed and remanded with regard to property division, spousal support, and child support; otherwise affirmed. Supplemental judgment for attorney fees reversed.