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¶ 8 (App. 2024); (explaining the increase in value of separate property remains separate unless the increase is "a result of the work effort of the community").

Rueschenberg, 219 Ariz. at 252 ¶ 12.

(addressing how to characterize an increase in value of separate property during the marriage); –92 (App. 1979) (resolving the effect of disclaimer deed on property acquired during the marriage).

If an asset is acquired during marriage with the profits of a separate-property business, and those profits contain both separate and community funds, the value of the acquired asset “must be apportioned accordingly.”

(“Property acquired by either spouse during marriage is presumed to be community property, and the spouse seeking to overcome the presumption has the burden of establishing the separate character of the property by clear and convincing evidence.”).

Generally, “[p]roperty acquired by either spouse during marriage is presumed to be community property.” see A.R.S.

Husband has shown no abuse of discretion, as the superior court was not necessarily bound by any one calculation method, but could select a method that appeared to “achieve substantial justice between the parties.” Saba II, 516 P.3d at 896, ¶ 16 ().

The spouse contending that the property acquired after the marriage is his or her separate property has the “burden of establishing the separate character of the property by clear and convincing evidence.”

If community property and separate property are commingled, the property is “presumed to be community property unless the separate property can be explicitly traced.” ( –54 (1979)).

¶9 It can be difficult, however, to determine whether a property’s increase in value is due to the community’s contributions or to other causes like simple market appreciation—a

NACKARD Decision of the Court contested businesses because Husband “transmuted and commingled [the inherited] separate property into community property.” ¶9 “Mere mutations of form do not of themselves work a transmutation of the character of property.”

¶ 34 (App. 2008); (stating, in such circumstances, “the burden is upon the spouse who contends that the increase is also separate property to prove that the increase is the result of the inherent value of the [business] itself and is not the product of the work effort of the community”) (emphasis added).

),” and Clause b which states that the account “shall remain the separate property of that party who brought such property into the marriage, including any appreciation, income, or other increase in property.” While “increases” includes appreciation growth during the time of marriage, an increase by its plain meaning does not include something added to it from an external and independent source, such as community labor and contributions, see id.