Whitepaper 05 · DivorceBusiness goodwill in a Florida divorce: the numbers.
Enterprise versus personal goodwill, the 2024 change to section 61.075, the three valuation approaches, normalization adjustments, and how to test a business’s books before anyone puts a value on them.
- Written for
- Florida family-law attorneys, CPAs and business-owner spouses
- Scope
- Florida law current to November 2026; valuation standards; forensic testing
- Author
- Geoffrey B. Davis Jr.
- Current to
- November 11, 2026 / 18 min read
Executive summary
When one spouse owns a business, the largest number in a Florida divorce is often the value of that business, and the largest disputed part of that number is usually goodwill. Florida has drawn the line for thirty-five years: goodwill that belongs to the enterprise is marital property; goodwill that is really the owner’s own reputation is not. Since July 1, 2024 that rule is written into the statute, together with fair market value as the standard of value.
The legal test only works if the numbers underneath it are honest. Valuation starts from historical earnings, and the owner controls the records that produce them. This paper sets out the Florida law, the professional standards appraisers follow, the normalization adjustments that turn tax-driven books into economic earnings, and the specific ways a business can be made to look smaller just before a divorce. It closes with a testing procedure for the financials and a plain statement of where a fraud examiner fits beside the credentialed appraiser.
Key findings
- 01
The test is now statutory
Section 61.075 makes enterprise goodwill a marital asset the court must value, sets fair market value as the standard and tells courts how to treat non-compete evidence.
- 02
Non-competes are evidence, not a verdict
Before 2024, appellate courts treated a buyer’s need for a non-compete as strong proof that goodwill was personal. The statute now says that evidence alone does not preclude enterprise goodwill.
- 03
Normalization moves the most money
Owner pay, personal expenses, related-party rent and one-time items can each change earnings, and earnings drive value under the income and market approaches.
- 04
Pre-divorce manipulation understates, not overstates
The schemes that matter in divorce push revenue out and expenses in: deferred billing, skimming, inflated payables and timed downturns.
- 05
Test the books before the valuation
A forensic review of completeness and accuracy should come before, and feed into, the appraiser’s opinion. It does not replace it.
What Florida law divides.
Florida divides marital property by equitable distribution. The court sets apart each spouse’s nonmarital assets and starts from the premise that the marital estate should be split equally, unless the statutory factors justify an unequal split.1 One of those factors is “the desirability of retaining any asset, including an interest in a business, corporation, or professional practice, intact,” which is why a business usually stays with the spouse who runs it and the other spouse receives offsetting assets or payments.1 That makes the business’s value the hinge of the whole distribution.
Thompson: goodwill can be marital, with a condition
The governing case is Thompson v. Thompson, decided by the Florida Supreme Court on January 10, 1991. The husband was a personal injury and medical malpractice lawyer and the sole shareholder of his professional association. The Fourth District had certified the question whether the association’s goodwill could be counted in valuing it. The court answered with “a qualified affirmative.”2
The qualification is the part that matters. Goodwill developed during the marriage is a marital asset, but “such goodwill, to be a marital asset, must exist separate and apart from the reputation or continued presence of the marital litigant.” Goodwill that depends on a particular person is “nothing more than probable future earning capacity,” relevant to alimony but not to the division of property. The court held that the existence and value of goodwill are questions of fact to be decided case by case with expert testimony, and directed that the fair market value approach be the exclusive method of measuring the goodwill of a professional association. Actual comparable sales are not required, “so long as a reliable and reasonable basis exists for an expert to form an opinion.”2
The 2024 amendment
House Bill 521, enacted as chapter 2024-237, Laws of Florida, was approved by the Governor on June 13, 2024 and took effect July 1, 2024. It added the closely held business paragraph quoted above to the statutory definition of marital assets.3 Thompson spoke of professional associations; the statute speaks of any closely held business, and it moves the non-compete question from case law into the text.
Dates and findings
Two dates do different work. The cut-off date for deciding which assets are marital is the earliest of a valid separation agreement, a date the agreement sets, or the filing of the petition. The valuation date is “the date or dates as the judge determines is just and equitable under the circumstances,” and different assets may be valued as of different dates.1 In a contested case, the judgment must identify the marital assets and include “the individual valuation of significant assets.”1
A business owned before the marriage is not automatically outside the estate. “The enhancement in value and appreciation of nonmarital assets resulting from the efforts of either party during the marriage or from the contribution to or expenditure thereon of marital funds” is marital.1 Our plain-language guide to business valuation in divorce walks through how that enhancement question is usually framed.
Personal or enterprise?
Goodwill is the value of a business beyond its tangible assets. Thompson adopted the Missouri Supreme Court’s description of professional goodwill as the tendency of clients “to return to and recommend the practice irrespective of the reputation of the individual practitioner,” and the shorter definition of goodwill as “the expectation of continued public patronage.”2 The question in every case is who that patronage follows: the business or the owner.
| Factor | Points toward personal goodwill | Points toward enterprise goodwill |
|---|---|---|
| Who serves the customer | The owner personally performs or closes most of the work | Employees, partners or systems deliver the service |
| Customer relationships | Clients came through the owner and deal only with the owner | Accounts are held by the firm, under contract or recurring |
| Name and brand | Business trades on the owner’s name and reputation | Trade name, brand, location or listings drive inquiries |
| Referral sources | Referrals are addressed to the owner by name | Referrals and repeat orders come to the business |
| Transferability | A buyer would need the owner to stay or to promise not to compete | A buyer would expect revenue to continue after the owner leaves |
| Comparable sales | Sale prices in the data depended on the seller’s continued involvement or covenants | Sale prices reflect businesses sold without the seller’s personal influence |
| Licenses and contracts | Revenue depends on the owner’s personal license or credentials | Contracts, permits and vendor terms belong to the entity |
No single factor decides the question. The weight of each depends on the business and on the evidence an expert can actually support.
Source: FES synthesis of the tests in Thompson and Held and the text of §61.075(6)(a)1.f.241
The non-compete line of cases
Before 2024, Florida’s district courts of appeal used the non-compete as a practical test. In Held v. Held, decided by the Fourth District on September 7, 2005, the parties had stipulated that the husband’s insurance agency had an adjusted book value of $2,918,655. The trial court valued the agency at $10,500,000, finding enterprise goodwill of $7,581,345, on the assumption that a buyer would require the husband to sign a non-solicitation agreement covering the agency’s 60 customer accounts.4
The Fourth District reversed. For the purpose of separating enterprise from personal goodwill, it held, “there is no distinction between a ‘non-solicitation/non-piracy agreement’ and a covenant not to compete,” because both limit the seller’s ability to deal with existing clients. The court also noted that the wife’s expert did not know whether the comparable sales he relied on depended on the sellers’ continued involvement or on restrictive covenants, information he conceded would have been “very beneficial.” The court directed the trial court to use the $2,918,655 book value on remand.4
Held collected the earlier cases. In Walton v. Walton, 657 So. 2d 1214 (Fla. 4th DCA 1995), involving a CPA practice, “the most telling evidence of a lack of any institutional goodwill was the wife’s expert’s testimony that no one would buy the practice without a noncompete clause.” The Second District described the same kind of testimony as “telling evidence of the lack of goodwill” in Williams v. Williams, 667 So. 2d 915 (Fla. 2d DCA 1996).4
The 2024 amendment changes the weight of that evidence. Courts must still consider whether a restrictive covenant would be required, but the covenant no longer ends the inquiry by itself.3 In practice that pushes the analysis back to the indicators in Exhibit 1: what, apart from the covenant, shows whether revenue would survive the owner’s departure.
Multi-owner practices
On June 21, 2024, shortly before the amendment took effect, the Fifth District decided Rosenberg v. Rosenberg, involving a physician’s interest in a practice with many physician-shareholders. It affirmed a valuation method that excluded the personal goodwill of all the physicians, not only the divorcing spouse, stating that “personal goodwill of a professional is simply not a marital asset in Florida.” The court certified the question to the Florida Supreme Court as one of great public importance.5 Counsel should check the status of that certified question before relying on the decision.
Standard of value, date and standards.
Fair market value
The statutory definition of fair market value tracks the federal tax definition almost word for word. Revenue Ruling 59-60, the IRS’s 1959 guidance on valuing closely held stock, defines fair market value as the price at which property would change hands “between a willing buyer and a willing seller when the former is not under any compulsion to buy and the latter is not under any compulsion to sell, both parties having reasonable knowledge of relevant facts.”6 Appraisers have used that ruling for decades, and its eight factors remain the usual checklist:6
- The nature of the business and the history of the enterprise from its inception.
- The economic outlook in general and the condition and outlook of the specific industry.
- The book value of the stock and the financial condition of the business.
- The earning capacity of the company.
- The dividend-paying capacity.
- Whether or not the enterprise has goodwill or other intangible value.
- Sales of the stock and the size of the block to be valued.
- The market price of stocks of similar companies that are actively traded.
The ruling also anticipates the problems this paper is about. It calls for profit-and-loss statements for a representative period, “preferably five or more years,” showing officers’ salaries “in total if they appear to be reasonable or in detail if they seem to be excessive,” so that the appraiser can “separate recurrent from nonrecurring items of income and expense.” It warns that a controlling owner “can substitute salaries and bonuses for dividends, thus reducing net income.”6
The valuation date matters for the evidence
Because the judge picks the valuation date, the period an appraiser relies on can shift from records kept before anyone thought of litigation to records the owner produced while the case was pending. That is why the testing procedure in § 07 looks at the trend across the whole period, not just the final year.1
Professional standards
- AICPA VS Section 100. The Statement on Standards for Valuation Services was issued in June 2007 and applies to engagements accepted on or after January 1, 2008. AICPA members must follow it when an engagement ends in a conclusion of value or a calculated value, including engagements for litigation.7 It requires the analyst to consider the income, asset and market approaches, and lists normalization adjustments and nonrecurring items among the matters to consider in applying the income approach.8
- Valuation versus calculation. VS Section 100 recognizes two engagement types. In a valuation engagement the analyst is free to choose the approaches and methods and reports a conclusion of value. In a calculation engagement the client and analyst agree on limited procedures and the result is a calculated value, which does not include all the procedures of a valuation engagement. Reports for certain controversy proceedings are exempt from the reporting provisions, but there is no litigation exemption from the development provisions.8 A calculated value offered as if it were a full valuation deserves a close look.
- NACVA Professional Standards. The National Association of Certified Valuators and Analysts publishes its own standards; the current version is effective for engagements accepted on or after June 1, 2023.9
- IRS Business Valuation Guidelines. The Internal Revenue Manual tells IRS appraisers that the three generally accepted approaches are asset-based, market and income, that all three should be considered, and that historical financial statements should be adjusted where necessary.10
Credentials
Three credentials are common in divorce valuation work. The ABV (Accredited in Business Valuation) is granted by the AICPA and requires valuation experience, an exam and continuing education.11 The CVA (Certified Valuation Analyst) is issued by NACVA.12 The ASA (Accredited Senior Appraiser) in business valuation is awarded by the American Society of Appraisers and requires five years of full-time appraisal experience and a review of a written valuation report.13
Three approaches, one conclusion.
Every credible valuation considers all three approaches and explains why it relied on some and not others.108 In a Florida divorce the approaches also have to produce a figure that fits the statute: fair market value, with personal goodwill taken out.1
| Approach | How it works | Where it fits | Goodwill question | Where manipulation bites |
|---|---|---|---|---|
| Income | Converts normalized earnings or cash flow to present value by capitalizing a single year or discounting a forecast | Operating businesses with a history of earnings: practices, agencies, contractors, distributors | The result includes all goodwill; personal goodwill must be identified and removed | Every dollar of understated earnings is multiplied by the capitalization factor |
| Market | Applies multiples from sales of comparable businesses or guideline public companies to the subject’s earnings or revenue | Industries with good transaction data and businesses that resemble the comparables | Comparable sale prices may embed the sellers’ personal goodwill or covenants, the defect Held identified | Understated revenue or earnings flow straight through the multiple |
| Asset | Restates assets and liabilities to fair market value; equity equals the difference | Holding companies, asset-heavy or loss-making businesses, and as a floor | Usually captures little or no goodwill unless intangibles are valued separately | Inflated payables, accruals or reserves reduce equity directly |
Thompson described goodwill as the excess of fair market value over the assets. In an income or market valuation, the gap between the indicated value and adjusted net tangible assets is where the personal and enterprise goodwill argument takes place.
Source: AICPA VS Section 100, paras. .31–.33; IRM 4.48.4; Thompson; Held.81024
Two points follow for counsel. First, the approach choice is not neutral. An asset approach in a service business often produces a lower number than an income approach because it leaves out most goodwill, so the reasons for choosing it should be tested. Second, under any approach the starting data are the business’s own records. If those records understate revenue or overstate expenses, the error carries into every approach that uses them. The next two sections deal with that problem.
Our case study of Pitt v. Jolie and the Château Miraval dispute shows how the value of a jointly held business interest can remain contested long after the divorce itself is settled, and why the record behind a number matters as much as the number.
Normalizing the numbers.
Closely held businesses keep books for tax and for the owner, not for a buyer. Normalization restates them to show the earnings a hypothetical buyer would actually acquire. The AICPA glossary defines normalized financial statements as statements “adjusted for nonoperating assets and liabilities and/or for nonrecurring, noneconomic, or other unusual items to eliminate anomalies and/or facilitate comparisons.”8
| Adjustment | Typical example | Effect on earnings | Evidence to test it |
|---|---|---|---|
| Owner compensation | Owner draws $90,000 in wages and takes the rest as distributions, or pays a large bonus in the year before filing | Restating pay to a market wage for the work performed can raise or lower earnings | Payroll records, W-2s and K-1s, duties and hours, market wage data such as BLS OEWS |
| Personal expenses | Family vehicles, phones, travel, club dues, home repairs or a spouse’s or child’s payroll booked as business expense | Adding them back raises earnings | General ledger detail, credit card statements, receipts, vehicle logs, payroll roster |
| Related-party rent | Business rents its building from the owner at above- or below-market rent | Restating to market rent moves earnings in either direction | Lease, property records, rent paid, market rent evidence from a real estate appraiser |
| Nonrecurring items | Lawsuit settlement, insurance recovery, storm damage, one-time consulting fee or government grant | Removing one-time income lowers earnings; removing one-time expense raises them | Source documents for each item and the multi-year trend showing it does not recur |
| Nonoperating assets | Excess cash, investment accounts, a boat or condo held in the company | Removed from earnings and valued separately so they are not double counted or missed | Balance sheet detail, bank and brokerage statements, titles |
| Related-party transactions | Purchases from or sales to entities owned by relatives or the owner | Restated to arm’s-length terms | Vendor and customer master files, entity ownership searches, contracts, pricing comparisons |
Examples are illustrative, not drawn from any client matter. The appraiser decides which adjustments belong in the valuation; the forensic task is to prove or disprove the facts each adjustment depends on.
Source: AICPA VS Section 100 glossary and para. .33; Rev. Rul. 59-60; IRS guidance on reasonable compensation; BLS OEWS.861415
Owner compensation in both directions
Owner pay is the largest adjustment in most small-business valuations, and it can be set for reasons that have nothing to do with the market. For S corporations, the IRS requires “reasonable compensation to a shareholder-employee” before non-wage distributions, and lists factors such as training and experience, duties, time devoted to the business, and “what comparable businesses pay for similar services.”14 The same factors are a sensible framework for the valuation adjustment. Public wage data help: the Bureau of Labor Statistics’ OEWS program publishes wage estimates for about 830 occupations at the national, state and metropolitan level, with May 2025 the latest reference date.15
Attorneys should check that the owner’s income figure used to value the business is consistent with the income figure used for alimony and child support. Thompson itself noted that personal goodwill, though not divisible, remains relevant to alimony.2
Personal expenses are also a disclosure issue
Personal spending run through a business is both a normalization adjustment and income the owner may not have reported on the financial affidavit. Our whitepaper on hidden assets in a Florida divorce covers how to trace it, and our guide to dissipation of marital assets addresses spending that goes further than ordinary personal use.
When the business has a bad year.
In most fraud work the concern is overstated results: fictitious sales that make a company look healthier to a lender or investor. In a divorce the incentive runs the other way. The owner benefits from a lower value, so the schemes that matter are the ones that move revenue out of the period, move expenses into it, or hide income altogether.
The ACFE’s fraud classification system recognizes this branch explicitly. Under financial statement fraud it lists “net worth/net income understatements” alongside overstatements, through timing differences, understated revenues, overstated liabilities and expenses, improper asset valuations and improper disclosures.16 It defines skimming as a scheme in which “an incoming payment is stolen from an organization before it is recorded on the organization’s books and records.”16 In a divorce, the owner who skims is often taking money from his own company; the victim is the marital estate.
Source: ACFE, Occupational Fraud 2026: A Report to the Nations, 2,402 cases in 143 countries and territories. These are occupational fraud figures, not divorce statistics.17
The ACFE figures do not measure divorce cases, but they make a relevant point: frauds committed by owners and executives are far larger than those committed by staff, because owners control the records and override the controls.17
Deferred or delayed billing
Invoices for completed work held until after the valuation date; work-in-progress or unbilled receivables climbing while revenue falls.
Revenue pushed into deferred accounts
Customer deposits or prepayments held as deferred revenue longer than the contracts justify, or recognition policies changed mid-case.
Skimming of cash receipts
Cash sales, tips or side payments falling relative to card sales, inventory purchases or industry norms; deposits that do not match the sales journal.
Inflated payables and accruals
New or enlarged accrued liabilities, reserves, or payables to relatives, insiders or entities the owner controls, especially near year end.
Sudden downturn
A decline that starts around the time of separation and is not matched by the industry, the customer base or the bank deposits.
Diverted customers or contracts
A new entity, often in a relative’s name, receiving business the company used to do; contracts not renewed and quietly reappearing elsewhere.
Payroll and expense loading
New hires, raises or consultants who do little work; personal expenses newly run through the company to cut reported earnings.
Prepaid expenses and inventory write-downs
Large prepayments to vendors before the valuation date or unexplained inventory write-offs and obsolescence reserves.
Any one of these can have an innocent business explanation. The pattern, the timing and whether the explanation survives the documents are what matter.
Source: Categories adapted from the ACFE Fraud Tree (net income understatements and skimming).16
For a closer look at how these schemes work in operating companies outside divorce, see our business fraud and financial investigations practice.
Testing the financials before valuation.
Florida’s mandatory disclosure rule gives the starting record. In a proceeding for equitable distribution, each party must serve, within 45 days of service of the initial pleading, a financial affidavit, three years of personal income tax returns, loan applications and financial statements prepared in the previous 24 months, and “corporate, partnership, and trust tax returns for the last 3 tax years” for any entity in which the party has an interest. A party claiming that an asset is nonmarital, or that a nonmarital asset was enhanced, must produce the supporting documents, and the duty to supplement continues when finances change.18
Mandatory disclosure is a floor. The general ledger, bank statements for every business account, payroll records, sales system data and customer lists usually come through formal discovery. The procedure below is how a forensic examiner uses those records to test the numbers before the appraiser relies on them.
- 01
Reconcile the sources
Tie the tax returns, internal financial statements, general ledger and bank deposits to each other for every year in the valuation period. Unexplained differences are the first list of questions.
- 02
Prove revenue independently
Rebuild revenue from deposits, merchant processor reports, customer records and third-party data, and compare it with reported sales. Look for cash, skimmed receipts and diverted customers.
- 03
Test the cut-off
Examine billing, deferred revenue, work in progress and payables around the valuation date and each year end. Look for revenue pushed out and expenses pulled in.
- 04
Support the adjustments
Document owner compensation, personal expenses, related-party rent and transactions, and nonrecurring items with source records, so each normalization adjustment rests on evidence.
- 05
Explain the trend
Compare the business’s results with its own history, its industry and the owner’s lifestyle. A downturn that begins at separation needs an explanation the documents support.
The output is a report of findings for counsel and the appraiser, not an opinion of value.
Source: Document categories from Fla. Fam. L. R. P. 12.285; adjustment categories from AICPA VS Section 100 and Rev. Rul. 59-60.1886
Two practical notes. Ask for native accounting files, not printed reports, so that edits, deleted transactions and journal entries posted after the fact are visible. And get the testing done before the valuation report is final, because an appraiser can only normalize what the record shows. Attorneys handling these matters can find more on how we support them on our divorce asset and income analysis page.
Examiner and appraiser: who does what.
Fraud Examination Service is not a business appraiser. Its principal holds no ABV, CVA or ASA credential and is not a CPA, and the firm does not issue business valuations, audits or tax advice. When a matter needs an opinion of value, a credentialed appraiser should give it. That is the right division of labor, and it makes both experts more useful.
Fraud examiner
- Tests whether the records are complete and accurate
- Traces cash, transfers and diverted revenue
- Reconstructs income and lifestyle when records are unreliable
- Documents the facts behind each normalization adjustment
- Identifies manipulation around the valuation date
- Testifies to findings of fact from the records
Credentialed appraiser (ABV, CVA, ASA)
- Selects and applies the valuation approaches
- Decides which normalization adjustments to make
- Separates personal from enterprise goodwill
- Develops capitalization rates, multiples and discounts
- Follows VS Section 100, NACVA or ASA standards
- Gives the opinion of fair market value
The examiner’s findings are inputs to the appraiser’s analysis and evidence for counsel; they are not a substitute for a valuation.
Source: Credential and standards references: AICPA, NACVA, ASA.79111213
Neutral or party experts
Florida’s family law rules apply the same procedural requirements to an expert appointed by the court and to one retained by a party. The court may not presume that a court-appointed expert’s opinion is correct, and any expert’s opinion is subject to cross-examination. The committee note records that the Fourth District has encouraged court-appointed experts to review financial information and reduce the cost of divorce litigation, citing Tomaino v. Tomaino, 629 So. 2d 874 (Fla. 4th DCA 1993).18
A forensic review fits either model. With a single neutral appraiser, both sides benefit from records that have been tested before the appraiser starts. With competing experts, the testing gives counsel an evidence-based way to challenge the other side’s inputs rather than arguing only about multiples and discount rates. For background on the discipline, see our guide to what a forensic accountant does, and for support at hearing or trial, our expert witness and litigation support services.
For attorneys and CPAs
Before the valuation report is final
- 01
Fix the date question early
Decide which valuation date you will argue for and which financial periods it puts in play, and make sure discovery covers them.
- 02
Ask for the native ledger
Request native accounting files, every business bank account and merchant processor reports, not just tax returns and printed statements.
- 03
Read the engagement type
Confirm whether the other side’s report is a valuation engagement or a calculation engagement and what procedures it omitted.
- 04
Test the goodwill evidence
Look past the non-compete. Assemble evidence on who serves customers, who holds the accounts and whether revenue would survive the owner’s exit.
- 05
Support every adjustment
Owner pay, personal expenses, related-party rent and one-time items should each rest on documents, not on the owner’s account.
- 06
Check the downturn
If results fell around the separation, compare deposits, billing and payables across the period before accepting the decline.
Talk to us about testing a business’s records before valuation
Common questions.
Short answers. The numbered notes link to the sources.
Only enterprise goodwill is. Since July 1, 2024, Florida Statutes section 61.075 says goodwill separate and distinct from the continued presence and reputation of the owner spouse is enterprise goodwill, a marital asset the court must value. Personal goodwill, which depends on the owner’s own skill and relationships, is not divided, although the Florida Supreme Court said in Thompson that it can bear on alimony.
Enterprise goodwill belongs to the business: customers, contracts, systems, staff, brand and location that would stay if the owner left. Personal goodwill belongs to the individual: patrons who come back because of that person’s reputation, skill or relationships. The practical test is what a willing buyer would pay for the business without the owner’s continued presence.
Not on its own. Older Florida appellate cases treated evidence that no buyer would purchase without a non-compete as strong evidence that goodwill was personal. The 2024 amendment to section 61.075 now requires courts to consider evidence that a restrictive covenant may be required, but says that evidence alone does not prevent a finding of enterprise goodwill.
Fair market value. Section 61.075 defines it as the price at which property would change hands between a willing and able buyer and a willing and able seller, neither under compulsion, both with reasonable knowledge of the relevant facts. The judge sets the valuation date or dates that are just and equitable, and different assets may be valued as of different dates.
They restate historical financial statements to show the earnings a buyer would actually acquire. Common adjustments replace the owner’s pay with a market wage, remove personal expenses run through the business, restate related-party rent to market and strip out nonrecurring items. Each adjustment should be supported by records, not by the owner’s description.
A fraud examiner tests whether the financial records are complete and accurate, traces diverted funds and reconstructs income, but a credentialed appraiser should issue the opinion of value. Fraud Examination Service is not an appraiser and does not issue business valuations. Its work gives the appraiser cleaner numbers and gives the attorney evidence to challenge numbers that were manipulated.
Endnotes
Sources and method.
Facts were checked on November 11, 2026 against the cited opinions, the 2025 Florida Statutes and the session law that amended them, the October 1, 2026 Family Law Rules, IRS guidance, and the standards bodies’ own pages. Where a case was reached only through a later opinion that quotes it (Walton, Williams, Tomaino), the text says so.
- 1The Florida Senate · 2025Florida Statutes §61.075, equitable distribution of marital assets and liabilities
- 2Florida Supreme Court (Justia copy) · January 10, 1991Thompson v. Thompson, 576 So. 2d 267 (Fla. 1991)
- 3Laws of Florida · Approved June 13, 2024Chapter 2024-237 (House Bill 521), equitable distribution of marital assets and liabilities
- 4Florida Fourth District Court of Appeal (FindLaw copy) · September 7, 2005Held v. Held, 912 So. 2d 637 (Fla. 4th DCA 2005)
- 5Florida Fifth District Court of Appeal (FindLaw copy) · June 21, 2024Rosenberg v. Rosenberg, Nos. 5D2023-1079 and 5D2023-1410
- 6Internal Revenue Service · October 29, 2014Valuation of non-controlling interests in S corporations: a job aid for IRS valuation analysts (Appendix A reprints Rev. Rul. 59-60, 1959-1 C.B. 237)
- 7AICPA and CIMA · Current textStatement on Standards for Valuation Services (VS Section 100)
- 8AICPA (reproduced copy) · As printed April 13, 2015VS Section 100, Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset, with interpretations and glossary
- 9National Association of Certified Valuators and Analysts · Effective June 1, 2023NACVA Professional Standards
- 10Internal Revenue Service · September 22, 2020Internal Revenue Manual 4.48.4, Business Valuation Guidelines
- 11AICPA and CIMA · Current textAccredited in Business Valuation (ABV) credential
- 12National Association of Certified Valuators and Analysts · Current textCertified Valuation Analyst (CVA)
- 13American Society of Appraisers · Current textBusiness Valuation: AM and ASA designations
- 14Internal Revenue Service · Current textS corporation compensation and medical insurance issues
- 15U.S. Bureau of Labor Statistics · May 2025 estimatesOccupational Employment and Wage Statistics (OEWS)
- 16Association of Certified Fraud Examiners · 2026The Fraud Tree: occupational fraud and abuse classification system
- 17Association of Certified Fraud Examiners · 2026Occupational Fraud 2026: A Report to the Nations, key findings
- 18The Florida Bar · October 1, 2026Florida Family Law Rules of Procedure (rules 12.285 and 12.365)
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This whitepaper is general information, not legal or tax advice. Talk to your attorney about your own matter.