In re Marriage of Cutler

Susan Cutler filed an action for dissolution of marriage against her husband of approximately 20 years, David E. Cutler. After a trial, the court entered a judgment on all remaining issues. One issue was the determination of the value of David’s business, the Cutler Insurance Agency (Cutler). The court valued the business at $243,000 by applying a form of the “income approach” method of valuation. This figure was then used in determining the equitable distribution of marital property. David now appeals, arguing that (1) the court’s valuation of the business was against the manifest weight of…