CALIFORNIA FAMILY LAW
...Business Interests
......Goodwill
.........Date of Valuation
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Assets are to be valued as near as practicable to the time of trial.

Earnings after date of separation are s/p.

Court may bifurcate issue of date of valuation.

General rule is that goodwill is valued as of date of separation, not date of trial.

Goodwill computation may not be based on H’s postseparation income.

May not include earnings after separation in goodwill calculations.

Improper to value goodwill by any method which utilizes postseparation earnings.

Law firm valued at date of trial instead of date of separation because spouse's efforts did not contribute to goodwill.

Change in value after separation due to efforts of operating spouse must be apportioned.

Where value of professional practice changes after separation due to efforts of owner, must allocate change between parties.