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¶21 When a party uses his or her separate property to pay post- petition community expenses, the court must account for the post-petition payments “in an equitable property distribution.” ¶ 19 (App. 2017).

§ 25-324(A), we may award fees taking into account “the financial resources of both parties and the reasonableness of the positions each party has taken[.]” ¶ 30 (App. 2017) (deciding attorney fee award on appeal under A.R.S.

When one party uses his separate property to pay community debt after the dissolution petition is filed, the court must account for the post-petition payments “in an equitable property distribution.” ¶¶ 18-19 (App. 2017).

-97, ¶¶ 15, 19-20 (App. 2017).

§ 25-211(A)(2), “the marital community is deemed to have terminated upon the service of a petition that results in a decree of dissolution.” ¶ 15 (App. 2017).

§ 25-213(B), separate funds used to pay a community expense post-service are not presumed to be a gift to the community, ¶ 15 (App. 2017).

¶¶ 15, 19 (App. 2017) (explaining that when a party uses separate funds to pay for community expenses after service of a petition for dissolution, that party is eligible for a reimbursement payment from the benefited party).

¶ 8 (App. 2022); ¶ 23 (App. 2017).

When a divorcing spouse pays post-petition community 3 HOWARD v. HOWARD Decision of the Court obligations, the presumption that those payments are a gift does not apply and the payments “must be accounted for in an equitable property distribution.” 596, ¶¶ 1, 19 (App. 2017).

-97, ¶¶ 19- 20 (App. 2017).

1 ¶ 19 (App. 2017) (“A spouse who voluntarily services community debt and maintains community assets with separate property should not be penalized when a mutual agreement cannot be reached; when such payments are made, they must be accounted for in an equitable property distribution.”).

¶ 10 (App. 2017); see also O’Hair v. O’Hair, -40 (1973).

¶ 25 (App. 2017) (quoting Maleki v. Desert Palms Pro.

§ 25-211(A)(2); ¶ 15 (App. 2017).

-96, ¶¶ 8, 15 (App. 2017).

247-48 (1984) (attorney fees in dissolution action concerning fully merged marital 12 IN RE MARRIAGE OF ROJAS Opinion of the Court settlement agreement controlled by § 25-324 rather than contractual prevailing-party provision); (against public policy to apply contractual prevailing-party provision in dissolution action).

See Burton, 205 Ariz. at 30, ¶ 16; ¶ 19 (App. 2017) (holding that payments out of the date of service for valuation of the various accounts.

Co., ¶ 12 (App. 2011) (holding that appellate courts may affirm the superior court’s ruling on any basis supported by the record); ¶ 19 (App. 2017).

It is true that “when a party voluntarily makes post-service payments toward community debt with separate funds, the superior court must account for the payments in its equitable property distribution.” ¶ 10 (App. 2022) ( ¶ 19 (App. 2017)).