Hoffmann v. Hoffmann

BLACKMAR, Judge,

concurring in part and dissenting in part.

I wholly agree in the principal opinion’s rejection of the “inception of title” rule as exemplified by several court of appeals opinions but never adopted by this Court, and in the espousal of the “source of funds” rule. The rule adopted accords with the purpose of the marriage dissolution statutes and gives trial judges the authority to approach the problems of holdings in close corporations realistically.

The “close corporation” is a significant concept in modern jurisprudence.1 A close corporation has many similarities to a partnership.2 An increase in value of shares in a close corporation is often the result of the personal services of major stockholders who are also officers or employees. The source of funds approach allows the trial court, given adequate proof, to treat a portion of the increased value of shares of stock as marital property, even though the shares were acquired prior to marriage. Any other approach would exalt substance over form and would greatly magnify the importance of the choice of business association.

I am not satisfied, however, that the appellant wife had full opportunity to present her theory to a trial court properly instructed in the doctrine which this Court now applies. The case below was tried before a master,3 who applied the “inception of title” rule as controlling law. The trial judge apparaently adopted the master’s findings, conclusions and recommendations as rendered. It is highly unlikely that the result below would have been affected by any evidence the wife might have adduced on the effect of her husband’s labors on the value of his shares in the corporation. The trial court also appears to have limited discovery substantially. The principal opinion holds that the points relied on in the appeal were not fully presented to the trial court. In court-tried cases it is often difficult to determine what was presented. I would opt for clarification.

The principal opinion argues that redemption of the husband’s father’s stock in 1964 was a neutral transaction because the redemption was at “book value.” Book *830value, however, is not a reliable guide to the true value of corporate stock.4 It rather is an accounting concept, based on the historic cost of acquisition of assets. There is the distinct possibility that the respondent might have derived a very substantial economic advantage through the use of corporate earnings for redeeming his father's stock. If the analysis relied on by the respondent’s expert in valuing his shares is sound, furthermore, his shares would derive increased value through an increase in the percentage of ownership. The appellant should have the chance to develop the redemption issue further, with opportunity for appropriate discovery.

Nor is it a sufficient analysis of the problem to suggest that the husband may have been adequately compensated for his efforts by salary, during the years of the marriage, so that no additional marital property would be created through increase in value of his shares. The persons in control of a closely held corporation have broad discretion in determining how much they want to take out of the corporation in salary and dividends and how much of the earnings they want to retain in the corporate treasury. Management often elects to plow back earnings in the hope of realizing future values, or because payouts would be subject to federal income tax. A decision which is entirely sound from the standpoint of corporate policy, still might operate to the disadvantage of a shareholder’s spouse so as to deprive the spouse of a share of the fruits of the shareholder’s labor. The spouse should not be required to demonstrate fraud or bad faith. It should be sufficient to show that the increase resulted from personal effort.

The partnership analogy is helpful. The income of a partnership must necessarily be reflected in the individual returns of each of the partners, and the income derived from the partnership by a married partner would be marital property. The difference should not be too great simply because the business is operated in corporate form.

The circumstance that the husband did not have majority voting control of the corporation is not significant. His associates have chosen him as chief executive officer, and he necessarily was in a position to exercise substantial influence over corporate decisions, including those affecting salaries and retention of earnings. Respondent was in the position of senior partner. The absence of absolute control should not operate to defeat his wife’s legitimate interests.

The principal opinion observes that some of the increased value of the shares was attributable to government policy which accentuated the demand for the company’s product. The trial court did not quantify the increase so occasioned, and the principal opinion concedes that a substantial portion of the increase was occasioned by respondent’s efforts. The record is not sufficient to permit us to reach a definitive conclusion.

Judge Gerald M. Smith, dissenting in the court of appeals, argued in favor of recognizing the rights of the spouse of a shareholder, while recognizing that there would be “substantial difficulties in evidence and proof.” I agree with his statement that these difficulties furnish no warrant for treating the spouse inequitably, and reject any suggestion that our courts are so overburdened that they do not have the time to do equity. I hope that this Court’s decision will point the way to trial courts and to attorneys as to what must be shown in order that the spouse of a shareholder may present the required proof. The present plaintiff, however, should have the opportunity to present additional proofs so that a properly instructed trial court could decide her rights based on the newly recognized principles in Judge Gunn’s opinion.

I concur in Parts II, V, VI and VII of the principal opinion, but would remand for *831further hearing touching Parts I, III and IV.

. F.H. O’Neal, Close Corporations, § 1.02 (1971); Galler v. Galler, 32 Ill.2d 16, 203 N.E.2d 577 (1964); Donahue v. Rodd Electrotype Co. of New England, Inc., 367 Mass. 578, 328 N.E.2d 505 (1975), specifying the principal characteristics of the "close corporation” as: "(1) a small number of stockholders; (2) no ready market for the corporate stock; and (3) substantial majority stockholder participation...." Id. at 586, 328 N.E.2d at 511.

. Donahue v. Rodd Electrotype Co. of New England, Inc., 367 Mass. 578, 586-87, 328 N.E.2d 505, 512 (1975); Ebrahimi and Westbourne Galleries, Ltd., [1973] A.C. 360; Blackmar "Partnership Precedents in a Corporate Setting—Exit From The Close Corporation”, 7 Journal of Corporation Law, 237 Winter 1982.

. The master was an experienced senior circuit judge, selected with the approval of the parties.

. Henn and Alexander, Law of Corporations, 3d Ed. (West, 1983), p. 766, fn. 18 and accompanying text.