Scott P Gyorke v. Shelly B Gyorke, 330375

Plaintiff earned all income during the marriage; defendant and plaintiff married prior to the 2014 tax year.
Plaintiff filed for divorce in September 2014; the trial court ordered the parties to maintain the financial status quo pending further order.
For 2014, the parties filed jointly; taxes owed were anticipated to be approximately $61,000 due by April 15, 2015.
CPA proposed paying $61,000 in one extension-based payment and applying the $38,000 2015 first-quarter estimate to that payment.
On August 12, 2015, the parties executed a settlement to maintain the status quo through September 30, 2015 and to divide marital accounts thereafter; divorce followed on November 3, 2015.
The trial court determined the $38,000 refund was marital and used to pay the 2015 first-quarter estimate; defendant challenged receiving half.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant is entitled to half of the 2014 tax refund	Gyor kept funds as marital assets to satisfy status quo obligations.	Gyor should receive half of the 2014 refund as a marital asset.	Denied; use of funds consistent with status quo; no reversal.

Hodge v Parks, 303 Mich App 552 (2014) (equitable distribution considerations)
Reeves v Reeves, 226 Mich App 490 (1997) (debt classification during pendency of divorce)
Lesko v Lesko, 184 Mich App 395 (1990) (presumption of marital debt; debt characterization)
Butler v Simmons-Butler, 308 Mich App 195 (2014) (factors for equitable distribution)
Woodington v Shokoohi, 288 Mich App 352 (2010) (standards for clear error review and equity)