In Re Marriage of Wikel v. Wikel
No abuse of discretion by court in ruling that only option that was exercisable as of the first day of trial would be considered part of the marital estate.
In Re Marriage of Maritato v. Maritato
Trial court has discretion to exclude non-exercisable stock options, to decline to divide underwater vested options and value the vested portion by subtracting the exercise value and taxes from the market value.
Heppner v. Heppner
Trial court’s refusal to consider stock option income for maintenance was an error of law. Trial court also erroneously exercised its discretion by excluding the options from property division even though they were “under water” because the options were earned while the parties were married.