Marriage of Marsden

The husband bought a house in 1962 for $38,300 using a down payment and loan proceeds; by the time he married the wife in 1971, the house's fair market value had risen to $65,000. During the marriage, the couple made community payments reducing the home loan's principal; the parties separated in 1978. The trial court calculated the husband's separate-property interest by adding his down payment to the loan proceeds, then subtracting the amount the community had paid down on the loan during the marriage, and dividing that figure by the original 1962 purchase price to get his separate-property percentage. The husband appealed, arguing he should also get credit for the home's appreciation between his 1962 purchase and the 1971 marriage, meaning his separate-property percentage should be calculated using the home's fair market value at the time of marriage rather than his original purchase price.