Edward Francis Zarnesky, Jr. v. Kathryn Christine Zarnesky, 03-13-00692-CV

Parties divorced in Bell County; trial court signed final decree on August 28, 2013, dividing the marital estate and awarding each party certain assets and debts.
At the final hearing Kathryn prepared and modified a property-division worksheet (Exhibit 1) using Edward’s proposed list; Exhibit 1 listed the Texas home's net value ($21,017) and also separately listed the mortgage ($124,983).
The trial court generally adopted Exhibit 1 in its division, awarding the Texas home and its mortgage to Kathryn and awarding retirement accounts to each party in their own names; written findings stated the court considered Exhibit 1 and testimony.
Edward (appealing pro se by telephone at the hearing) argued on appeal that the division was manifestly unjust because the trial court double-counted the mortgage—undervaluing the Texas home as an asset and thereby awarding Kathryn a disproportionate share.
The court of appeals reversed the portion of the decree dividing the marital estate and remanded for a new division, affirming the remainder of the decree; the opinion noted the double-counting error materially distorted the split.

Issue	Plaintiff's Argument (Zarnesky)	Defendant's Argument (Kyzer)	Held
Whether the marital-asset division was so disproportionate as to be an abuse of discretion	Trial court undervalued the Texas home by double-counting the mortgage in Exhibit 1, producing an unequal, manifestly unjust division	Trial court properly considered exhibits and testimony; the decree assigned assets and debts fairly and any perceived imbalance resulted from the worksheet	Reversed and remanded as to property division: the court found the mortgage was double-counted, which materially distorted the division and lacked a reasonable basis for inequality; remainder of decree affirmed
Whether appellant failed to preserve complaint about asset valuations / whether absence of trial court valuation findings precludes appellate review	Edward preserved his complaint about the effect of Exhibit 1 and the mortgage error; reversal is appropriate despite no specific trial valuation requests	Appellee argued no value findings were requested at trial, so appellant cannot now show what share each party received	Court concluded Edward preserved the complaint about the Texas home/mortgage and addressed the error on the merits; reversal on property division stands

Murff v. Murff, 615 S.W.2d 696 (Tex. 1981) (trial-court property-division reviewed for abuse of discretion)
O'Carolan v. Hopper, 414 S.W.3d 288 (Tex. App.—Austin 2013) (appellant bears burden to show division so disproportionate as to be an abuse)
Eggemeyer v. Eggemeyer, 535 S.W.2d 425 (Tex. Civ. App.—Austin 1976) (unequal division is permissible only if supported by reasonable basis)