Jayaram v. Jayaram (Appellate Division, Second Department)

The husband contends that the Supreme Court erred in concluding that his MBA degree and NASD licenses provided him with an enhanced earnings capacity subject to equitable distribution. The Appellate Court determined in accordance with the Supreme Court, that while the husband presented some evidence that an MBA was not an actual prerequisite to his employment at the brokerage firm, there was ample evidence to support the fact that this degree made the husband more attractive as a candidate in investment banking. The husband’s knowledge of the financial products, including options and derivatives, which were acquired during the MBA studies, assisted in his advancement. Furthermore, it was proper to award the wife 35% share of the enhanced earnings because she made substantial indirect contributions by supporting the husband’s educational endeavors, worked full time and contributed her earnings to the family while also being the primary caretaker of the family’s home and children.

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