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This decision contains a good explanation of the reasons why "fair value" is not necessarily appropriate to divorce cases....

Although the recession itself may be a subsequent event, many of economic factors that impair value after the recession were known or knowable before the recession....

The Alabama Court of Appeals recently issued an opinion in Grelier v. Grelier, holding that the parties’ agreement to employ the fair market value standard in a divorce case precluded wife from arguing on appeal that...