Chizmar, D. v. Chizmar, R., Chizmar, D. v. Chizmar, R. No. 1089 WDA 2016

Darlene and Ronald Chizmar married in 1998, separated in 2013; no children. Darlene is permanently disabled; Ronald is employed and a military retiree.
Darlene inherited fractional interests in two California properties (one-sixth and one-third). Parties disputed those properties' market value and the extent to which they should factor into alimony/equitable distribution.
A master conducted a two-day hearing and recommended indefinite alimony plus $500/month from Husband’s military retirement to Wife. The master rejected both parties’ property valuations.
Husband filed exceptions arguing (1) the master undervalued/failed to consider Wife’s property interests and rental potential when awarding alimony, and (2) the master failed to account for tax consequences of pension distributions.
Trial court granted Husband’s exceptions: converted indefinite alimony to a two‑year award and reduced the pension-derived payment to $400/month (to account for tax treatment), concluding the California properties had some value and the master improperly discounted them. Wife appealed.

Issue	Plaintiff's Argument (Chizmar — Wife)	Defendant's Argument (Chizmar — Husband)	Held
Whether trial court abused discretion by reducing indefinite alimony to two years	Wife: Permanent alimony required due to permanent disability, income/expense disparity, and uncertain/unrealizable value of inherited California properties	Husband: Master ignored that Wife has property resources; limiting term incentivizes Wife to realize value from properties; master improperly discounted evidence of value	Court: No abuse of discretion — trial court permissibly considered that the California properties had value, that alimony is secondary to equitable distribution, and alimony is modifiable on changed circumstances
Whether trial court erred in treating $500/month pension distribution as tax-free gift and reducing it to $400	Wife: Master failed to account for tax consequences; reduction to $400 labeled tax-free gift is incorrect and unlawful under tax law	Husband: Master overlooked tax consequences; trial court adjusted payment so Husband would pay income tax and Wife receive net amount tax-free (practical allocation)	Court: No error — trial court equitably adjusted amount to account for tax treatment and the master’s omission; payments characterized as distribution from pension (not alimony), and reduction was a proper remedy

Teodorski v. Teodorski, 857 A.2d 194 (Pa. Super. 2004) (explains purpose of alimony, factors for award, and availability of permanent alimony)
Smith v. Smith, 904 A.2d 15 (Pa. Super. 2006) (trial court has discretion in valuing assets and may rely on parties’ estimates, inventories, records, and appraisals)