master hearing in Pennsylvania

2024The trial court stated it was “unaware of whether this is a typo, but this date of separation change would be de minimus.” Id.

2018So we can certainly introduce evidence to that effect.” Id. (quoting N.T., 11/21/16, at 5).

2017"In determining the value of marital property, the court is free to accept all of the testimony, portions of the testimony, or none of the testimony regarding the true and correct value of the property." Aletto v. Aletto, 537 A.2d 1383, 1389 (Pa. Super. 1988) relying on Gee v. Gee, 460 A.2d 358 (Pa. 1983).

2016In support, Wife cites Biese, 979 A.2d at 897 (holding that under the Divorce Code, the value of the marital residence at the time of Master’s hearing, not the higher value at the time of separation, should have been used to determine increase in value); and Childress, 12 A.3d at 459 ) (holding that because the market value of the husband’s retirement accounts declined between the date of separation and the date of a hearing, a portion of the husband’s post-separation contributions was reduced and cannot be credited to the husband).

2015Although we understand Appellant’s desire to retain the marital home, none of Appellant’s claimed needs demonstrate that the trial court’s refusal to award her the marital home was “manifestly unreasonable, or the result of partiality, prejudice, bias, or ill will, as shown by the evidence in the certified record.” Kelly, 34 A.3d at 91 .

2014Did the [t]rial [c]ourt err in declining to consider that the child had been medically approved for social security disability benefits subsequent to the Master’s hearing and report and recommendation but prior to the argument in support of her exceptions to the Master’s proposed order, the fact of which the [t]rial [c]ourt was made aware at the argument on exceptions? ____________________________________________ 2 418 A.2d 403 (Pa.Super.1980). -5- J-A28035-14 Mother’s Brief, pp. 2-4.

2009Husband asserts that, had section 3501(a.l) been followed, the proper calculation would have resulted in the following: $255,000.00, the value in January 2008, less the $136,000.00 mortgage and less $72,000, the accurate amount of the home equity loan, resulting in a net home equity of $47,000.00, and a net increase in the value of the marital residence of $8,000.00. 1 ¶ 16 The trial court supported the Master’s use of the separation date valuation: The Master used the value of the home at the time of separation in his report and for equitable distribution purposes. [Husband] believes that the

2009Husband asserts that, had section 3501(a.l) been followed, the proper calculation would have resulted in the following: $255,000.00, the value in January 2008, less the $136,000.00 mortgage and less $72,000, the accurate amount of the home equity loan, resulting in a net home equity of $47,000.00, and a net increase in the value of the marital residence of $8,000.00. 1 ¶ 16 The trial court supported the Master’s use of the separation date valuation: The Master used the value of the home at the time of separation in his report and for equitable distribution purposes. [Husband] believes that the

2009Litmans , [449 Pa.Super.] at 235-236[, 673 A.2d at 394-395 ]. *899 Thus, the Litmans case and the notes to 23 PA.C.S. § 3501(a.l) indicate that if the property in question decreases in value from the time of separation until the time of the Master’s hearing, the value at the time of the Master’s hearing should be used only if there was an extended period of time between separation and the Master’s hearing.

1998Moreover, the Superior Court in interpreting similar legislation has concluded that there is a right to a de novo hearing in custody matters. 2 Ashford, v. Ashford, 395 Pa.Super. 125 , 576 A.2d 1076 (1990).

1998Moreover, the Superior Court in interpreting similar legislation has concluded that there is a right to a de novo hearing in custody matters. 2 Ashford, v. Ashford, 395 Pa.Super. 125 , 576 A.2d 1076 (1990).

1993Butler, 423 Pa.Super. at 538-540 , 621 A.2d at 664 .

1993Butler, 423 Pa.Super. at 538-540 , 621 A.2d at 664 .

1990The trial court, applying Sutliff v. Sutliff, 361 Pa.Super. 504 , 522 A.2d 1144 (1987), aff'd in part and rev’d in part, 518 Pa. 378 , 543 A.2d 534 (1988), which was not decided at the time of the Master’s hearing, concluded that wife was entitled to 50% of this income for the years 1982-1984, and denied wife any distribution for subsequent years.

1990The trial court, applying Sutliff v. Sutliff, 361 Pa.Super. 504 , 522 A.2d 1144 (1987), aff'd in part and rev’d in part, 518 Pa. 378 , 543 A.2d 534 (1988), which was not decided at the time of the Master’s hearing, concluded that wife was entitled to 50% of this income for the years 1982-1984, and denied wife any distribution for subsequent years.

1990The trial court, applying Sutliff v. Sutliff, 361 Pa.Super. 504 , 522 A.2d 1144 (1987), aff'd in part and rev’d in part, 518 Pa. 378 , 543 A.2d 534 (1988), which was not decided at the time of the Master’s hearing, concluded that wife was entitled to 50% of this income for the years 1982-1984, and denied wife any distribution for subsequent years.

1990The trial court, applying Sutliff v. Sutliff, 361 Pa.Super. 504 , 522 A.2d 1144 (1987), aff'd in part and rev’d in part, 518 Pa. 378 , 543 A.2d 534 (1988), which was not decided at the time of the Master’s hearing, concluded that wife was entitled to 50% of this income for the years 1982-1984, and denied wife any distribution for subsequent years.

1985Vajda v. Vajda, 337 Pa.Super. 573 , 487 A.2d 409 (1985); Jones v. Jones, 311 Pa.Super. 407 , 457 A.2d 951 (1983).

1985Vajda v. Vajda, 337 Pa.Super. 573 , 487 A.2d 409 (1985); Jones v. Jones, 311 Pa.Super. 407 , 457 A.2d 951 (1983).

1985Vajda v. Vajda, 337 Pa.Super. 573 , 487 A.2d 409 (1985); Jones v. Jones, 311 Pa.Super. 407 , 457 A.2d 951 (1983).

1985Vajda v. Vajda, 337 Pa.Super. 573 , 487 A.2d 409 (1985); Jones v. Jones, 311 Pa.Super. 407 , 457 A.2d 951 (1983).

1985Addressing this issue in Aloi v. Aloi, 299 Pa.Super. 400 , 445 A.2d 815 (1982), the Court did not find an abuse of discretion by the trial court in refusing to re-open the Master’s hearing.

1985Addressing this issue in Aloi v. Aloi, 299 Pa.Super. 400 , 445 A.2d 815 (1982), the Court did not find an abuse of discretion by the trial court in refusing to re-open the Master’s hearing.

1983Our denial of the appellant’s double jeopardy and due process claim is buttressed by our decision in In the *169 Interest of Stephens, 277 Pa.Super. 470 , 419 A.2d 1244 (1980) wherein we determined that inherent in the appellant’s choice to be heard by a Master is the understanding that his case might have to be heard again by a judge. 11 By the same token we consider David Perry to have recognized, implicitly, that the Master’s recommendations were subject to the written approval or confirmation of a judge as indicated in Section 6305(d), supra. In conjunction with his constitutional claims,

1983Our denial of the appellant’s double jeopardy and due process claim is buttressed by our decision in In the *169 Interest of Stephens, 277 Pa.Super. 470 , 419 A.2d 1244 (1980) wherein we determined that inherent in the appellant’s choice to be heard by a Master is the understanding that his case might have to be heard again by a judge. 11 By the same token we consider David Perry to have recognized, implicitly, that the Master’s recommendations were subject to the written approval or confirmation of a judge as indicated in Section 6305(d), supra. In conjunction with his constitutional claims,