In Re Marriage of Albrecht

I respectfully dissent, and would affirm the decision of the trial court, except for that portion of the trial court’s order which required the $23,000 award of marital property be paid at the rate of $350 per month. Such an installment award is contrary to the "clean break” philosophy of the Act and is justified only in exceptional circumstances.

For purposes of reimbursement under section 503(c)(2), there is a difference between improvements and maintenance. If improvements do not in fact improve the property, if they do not increase its value, then they should not give rise to any right to…