In Re Marriage of Kunze

At issue in this marital dissolution action is whether a “just and proper” division of property under ORS 107.105(1)(f) (1997), set out post, requires the inclusion of assets that wife had acquired separately from husband because wife integrated those assets into the parties’ joint financial affairs through commingling. The trial court excluded certain assets from the property division after determining that wife had proved that husband had not contributed to them. The Court of Appeals modified the property division as to two of the disputed assets, concluding that, although wife’s separate…