The Washington Supreme Court held that: (1) the increase in value of separate property is presumptively separate, unless the community claimant rebuts the presumption by direct and positive proof that community contributions caused the increase, and (2) the community is entitled to a share of the inflationary increase in the value of the separate property proportionate to the community contributions.
Elizabeth L. Wallin,
Community Property—Characterization of the Inflationary Increase in the Value of Separate Property Improved by Community Funds—In re Marriage of Elam, 97 Wn. 2d 811, 650 P.2d 213 (1982),
59 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol59/iss2/6