context: We agree that wife's future anticipated interest in the German "social security" benefits was an economic circumstance that could be considered in the equitable division of the marital estate.
citation_a.signal: cf.
citation_a.parenthetical: because no evidence was presented concerning the present value of wife's anticipated social security retirement benefits, court declined to address whether such benefits may be considered as an economic circumstance
citation_a.sentence: See In re Marriage of Jones, 812 P.2d 1152 (Colo.1991) (although spouse’s expectancy interest in a trust was not property, it should be considered as an economic circumstance under § 14-10-113(l)(c) in determining a just division of marital property); In re Marriage of Simon, 856 P.2d 47 (Colo.App.1993)(receipt of social security disability benefits may be considered as an economic circumstance in the division of property); cf. In re Marriage of James, 950 P.2d 624 (Colo.App.1997)(because no evidence was presented concerning the present value of wife’s anticipated social security retirement benefits, court declined to address whether such benefits may be considered as an economic circumstance); see also In re Marriage of Boyer, 538 N.W.2d 293 (Iowa 1995); In re Marriage of Knipp, 15 Kan. App.2d 494, 809 P.2d 562 (1991); Pongonis v. Pongonis, 606 A.2d 1055 (Me.1992); Elliott v. Elliott, 274 N.W.2d 75 (Minn.1978); Hogan v. Hogan, 796 S.W.2d 400 (Mo.App.1990).
citation_b.signal: see
citation_b.parenthetical: although spouse's expectancy interest in a trust was not property, it should be considered as an economic circumstance under SS 14-10-113(l
citation_b.sentence: See In re Marriage of Jones, 812 P.2d 1152 (Colo.1991) (although spouse’s expectancy interest in a trust was not property, it should be considered as an economic circumstance under § 14-10-113(l)(c) in determining a just division of marital property); In re Marriage of Simon, 856 P.2d 47 (Colo.App.1993)(receipt of social security disability benefits may be considered as an economic circumstance in the division of property); cf. In re Marriage of James, 950 P.2d 624 (Colo.App.1997)(because no evidence was presented concerning the present value of wife’s anticipated social security retirement benefits, court declined to address whether such benefits may be considered as an economic circumstance); see also In re Marriage of Boyer, 538 N.W.2d 293 (Iowa 1995); In re Marriage of Knipp, 15 Kan. App.2d 494, 809 P.2d 562 (1991); Pongonis v. Pongonis, 606 A.2d 1055 (Me.1992); Elliott v. Elliott, 274 N.W.2d 75 (Minn.1978); Hogan v. Hogan, 796 S.W.2d 400 (Mo.App.1990).