In RE the Marriage of Diana L. Kimbro and Steven C. Kimbro Upon the Petition of Diana L. Kimbro, 826 N.W.2d 696

Iowa Supreme Court reviews dissolution of marriage between Steven and Diana Kimbro; district court ordered an equalization payment totaling $50,060, later amended to $45,468 to reflect tax considerations, and awarded Diana custody of two minor daughters with child and spousal support.
Steven unilaterally withdrew $226,518 from a jointly held Bankers Trust account the day after Diana announced divorce, transferring it to a Bank Iowa account in his name.
No predissolution agreement to divide the Bankers Trust funds was proven; the court found no written or oral agreement supporting Steven’s claim.
Court of Appeals reduced the equalization payment to $5,000; on review, the Iowa Supreme Court vacates that part and affirms the district court’s $45,468 equalization payment.
Court of Appeals and district court denial of trial and appellate attorney fees is affirmed; the judgment overall is affirmed except the equalization amount is reinstated at $45,468.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the equalization payment amount appropriate?	Kimbro argues equalization should be reduced due to dissipation.	Kimbro argues there was predissolution agreement or appropriate reduction.	Equalization payment of $45,468 affirmed; not reduced.
Did Diana dissipate marital assets to reduce the estate value?	Diana dissipated funds from the Bankers Trust account.	Diana used funds for legitimate living and family expenses.	Dissipation not proven; expenditures were reasonable and not dissipation.
Was there an agreement governing the Bankers Trust funds?	Steven claimed a predissolution agreement to divide funds.	Diana testified there was no such agreement.	No evidence of an agreement; funds not subject to an agreement.
Should attorney fees be awarded to Diana or Steven?	Diana sought attorney fees based on economic disparity.	Both parties can pay their fees; Diana has some income.	Both denied trial and appellate attorney fees; decision affirmed.

In re Marriage of Johnson, 350 N.W.2d 199 (Iowa 1984) (Oral agreement to divide property possible if proven; not applicable here)
In re Marriage of Burgess, 568 N.W.2d 827 (Iowa Ct. App. 1997) (Dissipation factors considerations in property division)
In re Marriage of Fennelly & Breckenfelder, 737 N.W.2d 97 (Iowa 2007) (Two-pronged dissipation test and factors for dissipation)
In re Marriage of Goodwin, 606 N.W.2d 315 (Iowa 2000) (Need to show expenditures were paid with the disputed funds)
In re Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006) (Tax debts and marital obligations context in division)
In re Schenkelberg, 824 N.W.2d 481 (Iowa 2012) (Equitable distribution framework and de novo review)