The Complete Guide to Illinois Property Division and Asset Protection in Divorce

Published: 11/21/2025 • 94 min read
By Jonathan D. Steele
The Complete Guide to Illinois Property Division and Asset Protection in Divorce

Illinois divorce law sets out a detailed framework for how property is classified and divided between spouses. Unlike community property states that split marital assets 50/50, Illinois follows an equitable distribution model under the Illinois Marriage and Dissolution of Marriage Act (IMDMA). This means assets and debts are divided “in just proportions” based on multiple factors, not necessarily equally. In this comprehensive guide, we’ll explain Illinois’ property division rules (750 ILCS 5/503), how to distinguish marital vs. non-marital property, strategies for dividing complex assets (businesses, retirement accounts, stock options, cryptocurrency, real estate, etc.), protecting assets (through agreements and smart planning), and common pitfalls to avoid. We’ll also cover recent Illinois cases (2020–2025) that illustrate key principles, and provide checklists and decision-tree examples to help you navigate property division with confidence.

Equitable Distribution vs. Community Property: Illinois’ Approach

Illinois is an equitable distribution state, meaning courts aim for a fair division of marital assets and debts, rather than an automatic 50/50 split. In contrast, community property states generally divide marital property equally. Under Illinois law, the court “shall divide the marital property without regard to marital misconduct in just proportions” after considering all relevant factors. In practice, many Illinois divorce settlements end up in a range like 50/50, 60/40 or even 70/30 – whatever allocation the judge deems equitable given the circumstances. In rare cases, one spouse might receive virtually all marital property (for example, if the other spouse has significant non-marital assets or engaged in extreme misconduct that dissipated assets). Equitable does not always mean equal.

Key factors in “just proportions”: Illinois law lists 12 factors that courts must weigh to determine an equitable distribution. These include:

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The judge must make specific findings on what is marital vs. non-marital property, each asset’s value, and how the factors justify the ultimate division. It’s important to note that marital misconduct (e.g. cheating) is explicitly not a factor in property division. So, even if infidelity ended the marriage, the property will be divided without penalizing the “at-fault” spouse for that behavior. Illinois’ focus is on financial fairness, not moral judgments, in dividing assets.

Illinois Property Division Framework (750 ILCS 5/503)

Illinois’ property division rules are codified in Section 503 of the IMDMA. Understanding this framework is crucial. The process can be broken down into three general steps:

  1. Identify and classify each asset and debt as either marital or non-marital property.
  2. Value the property (determine fair market values of assets and balances of debts, as of an appropriate date).
  3. Divide the marital property between the spouses in equitable proportions, and assign each spouse their non-marital property.

Any property acquired by either spouse after the marriage and before a divorce judgment is presumed marital. This includes not only assets like real estate, bank accounts, investments, and personal property, but also debts and liabilities. Marital property will be divided, while each spouse generally keeps their own non-marital property.

Illinois law defines “marital property” broadly, with specific exceptions for non-marital property. By statute, the following are non-marital property even if acquired during the marriage (750 ILCS 5/503(a)):

All other property acquired during the marriage that doesn’t fall under an exception is marital property by default. It doesn’t matter which spouse’s name is on the title or account – if it was acquired during the marriage, it’s presumed marital even if only one spouse’s name is on it. (For instance, if a car is titled just in Husband’s name but bought with marital funds during the marriage, it’s marital property. Similarly, a retirement account in Wife’s name that had contributions during marriage is marital to the extent of those contributions.) Each spouse has a species of common ownership in the marital assets that “vests” when a divorce is filed, but this doesn’t give either the right to transfer or encumber assets unilaterally – it’s more of a conceptual recognition that both have an interest until division.

Classification can get complicated when marital and non-marital funds are mixed, or when an asset has both marital and non-marital components. Illinois law provides detailed rules for commingled property and reimbursement between estates:

After classifying assets and debts, the court values the marital property. Illinois gives courts discretion on valuation dates – it can be the trial date or another date as fairness requires. For volatile assets (like stocks or cryptocurrency), a court might use a valuation date close to distribution. Each asset should have a specific dollar value (or a range) determined, often requiring appraisals for real estate, actuaries for pensions, accountants or experts for business interests, etc. Both parties typically submit evidence or expert testimony if values are disputed. For example, in a recent high-asset case In re Marriage of Rozdolsky (2024), the value of the husband’s business became a major point of contention – the wife’s expert valued it at ~$60.7 million while the husband’s expert said ~$20.2 million. The court found the true value to be about $49 million before personal goodwill, and ultimately $42.45 million after excluding the owner’s personal goodwill, illustrating how courts weigh expert opinions and adjust for factors like goodwill.

Finally, the court divides the marital property in light of the statutory factors (outlined in the previous section). The judge will typically issue a written order or opinion explaining which factors were most relevant and how each major asset is allocated or sold. Marital debts are also apportioned between spouses as part of this division (e.g. who will pay the remaining mortgage, credit card bills, tax obligations, etc.). The goal is for the overall division to be equitable. For instance, one spouse might receive the marital home and 40% of investments, and the other spouse 60% of investments plus most of the bank accounts, to balance things out. It’s not asset-by-asset (each asset need not be split); it’s the fairness of the total distribution that matters.

Example: John and Jane have a marital estate worth $1,000,000. Jane has primary custody of their two young children and a lower income. John has a high-paying job and significant separate investments. To be equitable, the court might award Jane about 60% of the marital assets (e.g. $600,000) and John 40% ($400,000) to account for Jane’s greater need and lower future earning potential. Jane might receive the marital home (with $250,000 equity) plus $350,000 in investments and cash, while John keeps the remaining $400,000 in retirement and brokerage accounts. This 60/40 split is “just” given the circumstances – it helps ensure the children’s home is preserved and recognizes John’s stronger ability to recover financially.

Once the court’s division is final, each spouse is ordered to transfer any assets necessary to effectuate the judgment (or to sign a QDRO for retirement accounts, etc.). If an asset is ordered sold (like a house or business), the court might retain jurisdiction to oversee that the sale happens and the proceeds are split appropriately. The court can even order an asset sold by a certain date or appoint a receiver if one party refuses to cooperate, though such extreme measures are not common unless there’s no other way to fairly divide the property. (We will discuss shortly the limitations on forcing a sale of the marital home before the divorce is final.)

Marital vs. Non-Marital Property: Protecting Your Separate Assets

One of the most critical aspects of Illinois property division is the distinction between marital and non-marital property. Getting this classification right can hugely impact the outcome – since non-marital assets are set aside to the owning spouse and not divided. Below, we delve deeper into how to determine what’s marital vs. non-marital, and how to preserve the identity of your non-marital assets (asset protection begins with not accidentally turning your separate property into marital property!).

Tracing and maintaining non-marital property. If you have assets that you owned before marriage or received by gift/inheritance, keep careful records and avoid commingling with marital funds. In Illinois, the burden is on the spouse claiming an asset is non-marital to prove it by clear and convincing evidence. For example, if you had $50,000 in savings before marriage, and during the marriage you deposited marital earnings into the same account and paid bills from it, that account may transmute into marital property because the non-marital funds lost their separate identity. To protect such assets, you might keep them in a segregated account in your sole name and avoid using that account for joint expenses. Likewise, if you use non-marital funds to buy a new asset (like selling a car you owned pre-marriage to buy another car), document the transaction to show it was an exchange of non-marital property for new non-marital property.

Illinois law gives some relief through reimbursement: even if non-marital property is commingled and becomes marital, you can claim reimbursement for the contribution as long as you can trace it. But litigation over tracing can be complex and costly (involving forensic accountants to follow paper trails). It’s better to avoid the fight by not mixing assets in the first place. Consider the following checklist of strategies to maintain the non-marital nature of assets:

Debts can be non-marital too. Just as assets acquired before marriage are non-marital, debts incurred before marriage remain with that spouse. If your spouse brought significant student loans or credit card debt from before the wedding, those are typically their own responsibility after divorce. Similarly, a business loan taken out by one spouse before the marriage stays their debt. However, interest paid on that loan from marital funds during the marriage could give rise to a reimbursement claim by the marital estate, since marital money was used to service a non-marital debt.

Dissipation and hidden transfers. A unique aspect of Illinois law is dealing with a spouse who intentionally depletes marital assets when a divorce is on the horizon. If one spouse is siphoning off funds, gifting money to friends or a new partner, gambling excessively, or otherwise “wasting” assets for a purpose unrelated to the marriage, the other spouse can claim dissipation. Illinois requires a formal notice to be filed to claim dissipation, specifying when the marriage began breaking down and the amounts dissipated. You can generally look back only a few years: no dissipation claims for acts more than 5 years before the divorce filing or more than 3 years after you knew (or should have known) of the dissipation. If proven, the court will typically add the dissipated amount back into the marital ledger on the spending spouse’s side. For example, if a husband drained $50,000 from an account during the divorce to take an extravagant vacation with a girlfriend, the court might award the wife $50,000 extra in assets (or reduction in what husband receives) to offset that. Forensic accounting can help uncover dissipation and hidden transfers – more on that in the hidden assets section.

Illinois case spotlight: In re Marriage of Brubaker, 2022 IL App (2d) 200160 demonstrates the importance of full disclosure. In that case, the wife failed to disclose an $800,000 condo during the divorce, and they had waived formal discovery. Years later, the husband discovered this hidden asset and moved to reopen the case. The trial court initially denied it (saying the husband should have done formal discovery), but the Appellate Court reversed, allowing the judgment to be vacated for the wife’s fraudulent concealment. The lesson: attempts to hide significant assets can backfire badly – leading to re-division of property and potential sanctions. Indeed, Illinois courts have little tolerance for gamesmanship; in one 2024 case, a husband who refused to turn over business financial records during discovery was ordered to pay $1.1 million of the wife’s attorney and expert fees. Transparency is not just ethical – it’s essential under the law.

Dividing Complex Assets: Businesses, Retirement Accounts, Investments, and Crypto

Not all assets are straightforward to split. Illinois couples with complex or high-value assets face additional challenges in valuation and division. Below we address several common complex asset types and how they’re handled in divorce:

Business Interests & Professional Practices

When a spouse owns a business or professional practice (doctor, lawyer, consultant, etc.), it can be one of the most challenging assets to divide. First, determining whether the business (or a portion of it) is marital property is key. If the business was started during the marriage with marital funds or efforts, it’s clearly marital. If it was started before marriage but grew during the marriage, the growth in value may be partly marital (subject to reimbursement to the marital estate). Illinois courts will classify and then value the business.

Valuation of a business typically requires a financial expert, such as a business appraiser or CPA. Common valuation methods include:

In Rozdolsky (2024), for example, two valuation experts came in tens of millions apart on a manufacturing company’s value. The court scrutinized each expert’s assumptions: it criticized the husband’s expert for using a pandemic-year low earnings and minimal growth rate, and noted errors like wrong risk premiums. It found the wife’s expert more credible but still adjusted down some overly optimistic projections. Ultimately the court arrived at its own figure of ~$42.4 million and the Appellate Court upheld it, since it was reasoned and supported by evidence. The takeaway is that courts have discretion to accept or blend expert opinions – and having a qualified valuation expert is crucial to protect your interests.

Marital vs. personal goodwill: Illinois distinguishes enterprise goodwill (value associated with the business entity) from personal goodwill (value attributable to the individual owner’s reputation or skills). Personal goodwill is typically not a divisible marital asset – because if the owner-spouse leaves, that goodwill doesn’t accrue to the other spouse. In professional practices, much of the value may be personal. Illinois case law (e.g. In re Marriage of Zells, though older) held that you cannot “double count” a professional’s future earning capacity as an asset. In Rozdolsky, the court explicitly accounted for the husband’s personal goodwill in the company, reducing the value by 15% to exclude that portion. This prevents the non-owner spouse from getting a piece of the spouse’s future earning potential beyond the business itself.

Division approaches for businesses: Courts usually will not force a sale of a closely-held business in a divorce (especially if it’s a family business or the primary income source). Instead, common outcomes are:

For business owners, an important strategy is to gather solid documentation of the business’s financials: tax returns, profit/loss statements, balance sheets, customer or contract lists, etc. Not only will this be required in discovery, but it helps combat any attempt by the other side to undervalue or inflate the business. Be aware of potential “red flags” like sudden dips in revenue or paying personal expenses through the business (courts and forensic accountants will look for efforts to depress value). In one case, a husband who resisted providing full financial records saw the court penalize him by ordering him to cover the wife’s $1.1 million expert and attorney fees – an expensive reminder to comply with discovery and be forthright.

Also consider tax implications: if the business is a corporation or LLC, transferring interests might have tax consequences. However, transfers between spouses as part of a divorce are generally tax-free (IRC §1041) – no gain is recognized. But if the business is an S-corp or partnership, there might be built-in gains or loss of future depreciation benefits to consider. It’s wise to consult a tax advisor when structuring a buyout (e.g. installment payments vs. lump sum) to understand any indirect tax effects.

Retirement Accounts and Pensions

Retirement assets often represent a large portion of a couple’s net worth. In Illinois, contributions to retirement plans during the marriage are marital property (regardless of whose name the account is in). This covers 401(k)s, 403(b)s, IRAs, pension plans, etc. The challenge is in dividing these accounts properly and handling tax issues.

Defined contribution plans (401(k), 403(b), TSP, etc.): These have account balances that can be readily valued from statements. If the entire account is marital, the court may simply split the balance (not necessarily 50/50 – could be 60/40, etc., as part of the overall scheme). If a portion is non-marital (e.g. you had $50k in your 401k before marriage), an actuary or financial expert might help calculate the marital portion (usually contributions and growth during marriage). To divide these without tax consequences, a Qualified Domestic Relations Order (QDRO) is used. A QDRO is a court order that tells the plan administrator to allocate a portion of the funds to the other spouse (now called the alternate payee). With a QDRO, the transfer is tax-free and penalty-free – each spouse can then roll their share into their own IRA or keep it in a separate account under the plan. It’s critical to get a QDRO prepared and approved (often by an attorney or QDRO specialist) because if you just withdraw money and give it to your ex without a QDRO, it will likely be taxed and penalized.

A spouse receiving funds via QDRO has a one-time opportunity to take a cash distribution from a qualified plan without the 10% early withdrawal penalty (if under age 59½). For example, if as part of the settlement you need some cash, you could have, say, $50,000 of the 401(k) assigned to you via QDRO paid directly to you instead of rolled over. You’ll pay ordinary income tax on that withdrawal, but no 10% penalty. However, the plan will withhold 20% for taxes by default, so net ~80% reaches you and you’ll settle the actual tax at filing. Any remaining funds you should roll into an IRA to avoid taxes. A cautionary example from a tax advisor: one ex-wife planned to withdraw $40k to buy a car, so she had to actually take $50k due to 20% withholding, and that $50k counted as taxable income, bumping her into a higher tax bracket. So if you must use retirement funds for immediate needs, consult a financial planner to minimize tax impact.

Pensions (defined benefit plans): Pensions promise a stream of monthly payments at retirement. They can be trickier – you can’t “split the account” because there’s no account balance per se (unless the plan offers a lump-sum value). One approach is to calculate the present value of the pension (requiring actuarial expertise) and offset that value with other assets – for example, one spouse keeps the entire pension (receiving all future payments) and the other spouse gets more of the 401(k)/house now to compensate. The other approach is to use a QDRO or QILDRO (Qualified Illinois Domestic Relations Order) to split the pension payments. Illinois public pensions (which are not governed by ERISA) use a QILDRO mechanism for division. A common formula for pensions is the “Hunt formula” or coverture fraction: the marital portion is proportional to the years of service during marriage over total service years. The non-employee spouse can be awarded (via QDRO/QILDRO) typically half of the marital portion of each payment when it comes due. For example, if a spouse was in the pension 20 years, and 10 of those were during the marriage, the marital portion is 10/20 = 50%. If the court splits that marital portion equally, the spouse would get 25% of each pension payment. Those payments will be taxable to the recipient when received (as pension income).

It’s important to file any required QDROs promptly after the divorce. If a participant spouse dies before a QDRO is in place, the surviving ex may lose out on benefits unless specific precautions were in the decree. Also, for pensions, ensure the decree addresses survivor benefits (so that if the employee spouse dies, the ex-spouse can continue to receive a share or be treated as a surviving spouse for that portion). These details often require careful drafting.

IRAs: Splitting IRAs doesn’t require a QDRO; a simple transfer incident to divorce (direct trustee-to-trustee transfer from one spouse’s IRA to an IRA for the other) can be done tax-free. But you must have the divorce judgment specify the transfer. Like with 401ks, if an IRA is split and one spouse takes a cash distribution, that’s taxable and subject to penalty if under 59½ (there’s no special penalty exception on IRAs for divorce transfers, that only applies to qualified plans). So you usually roll the IRA funds over intact.

Restricted stock units, stock options, and deferred compensation

Many executives and employees receive part of their compensation in forms that vest over time or have future payout dates (stock options, RSUs, performance shares, deferred bonuses, etc.). Under Illinois law, stock options and similar benefits granted during the marriage are presumed marital property – whether vested or not. The challenge is determining how to divide them, especially if they vest after the divorce or are tied to future performance.

Courts can use a few methods:

For example, suppose the husband is granted 1,000 RSUs during the marriage that vest 3 years later (after the divorce). If at divorce he’s 1 year into the vesting period, one might classify 1/3 of the units as marital. The wife could then get, say, half of that marital portion (1/3 of 1,000 = ~333 units marital, half to wife = ~167 units) when they vest. The QDRO or settlement would specify that she receive the shares or their value at vesting. Tax-wise, when they vest, the employee spouse will have wage income and taxes withheld, but the QDRO can sometimes allow direct share distribution to the ex or an equivalent payout. It gets technical, but the important part is making sure the divorce judgment addresses these assets so they aren’t forgotten (a common mistake is overlooking executive comp packages until after the divorce is done).

Cryptocurrency and Digital Assets

Cryptocurrencies (Bitcoin, Ethereum, etc.) and other digital assets (like NFTs, or even things like frequent flyer miles or credit card points) have become more common in divorces. In Illinois, crypto acquired during the marriage is treated as marital property – there’s nothing magical about digital currency in the eyes of the law. However, crypto poses unique issues:

Both spouses should ensure that all digital assets are listed in financial affidavits and discovery responses. A savvy way to catch hidden digital assets is to examine the tax returns for any mention of cryptocurrency (the IRS now asks on Form 1040 if you dealt in crypto), and to review bank statements for transfers to known crypto exchanges or unusual tech-savvy transactions. Hiring a forensic expert can be worthwhile if significant assets are unaccounted for.

Real Estate Division Strategies: The Marital Home and Beyond

The marital home is often the asset with the most emotional attachment – and a significant financial value. Deciding what happens to the house (or any real estate, like vacation homes or investment properties) is a key part of divorce negotiations. Common strategies include one spouse keeping the home (and “buying out” the other’s share), selling the home and splitting the proceeds, or in some cases a deferred sale (waiting to sell until a later date). Each approach has pros and cons, and in Illinois the court will consider the statutory factors like the needs of any children and each spouse’s financial situation. Let’s explore these options and some Illinois-specific rules:

1. One Spouse Keeps the Home (Buyout): If one spouse (often the custodial parent) wishes to remain in the home, they can “buy out” the other spouse’s equity. The equity is the value of the home minus any mortgage debt. For example, if the home is worth $400,000 and $100,000 is owed on the mortgage, the equity is $300,000. If the parties are roughly splitting assets, the spouse keeping the house might refinance the mortgage into their sole name and pull out $150,000 to pay the other spouse for their half of equity. Or they might give the other spouse other marital assets worth $150,000 (for instance, a retirement account or other investments) in lieu of cash. A buyout keeps the kids in their home (if applicable) and avoids realtor fees. The spouse keeping the home needs to be able to qualify to refinance and afford the mortgage and upkeep on their own, which is a practical constraint.

Sometimes the agreed buyout value is adjusted for expected selling costs that are avoided. For instance, if they would have paid 6% realtor fees and some taxes on a sale, they might discount the buyout price a bit accordingly (though this is negotiable).

2. Sell the Home Now and Split Proceeds: In cases where neither spouse can afford to keep the home alone, or neither wants it, the home will be sold. The divorce judgment can specify the sale process: listing price, how to choose a realtor, who pays the expenses until sale, and how net proceeds will be divided (often equally, or in some other ratio like 60/40 if that’s the equitable distribution). Selling provides a clean break and liquidity. However, it can disrupt the family, especially if children are involved, and timing the sale (given housing market conditions) adds complexity. If the market is down, spouses might argue over whether to sell immediately or wait for a better price. Generally, courts prefer not to force a sale of the home before the divorce is finalized unless absolutely necessary (see the next point on temporary sales).

3. Deferred Sale (Temporary Post-Divorce Co-Ownership): Sometimes called “birdnesting” (when involving kids) or simply a delayed sale, this arrangement lets one spouse (often with children) continue living in the house for a set time after divorce, with the sale to happen later. For example, spouses may agree that the wife and kids live in the home until the youngest finishes high school, then the house will be sold and proceeds split. In the interim, both might share responsibility for the mortgage and taxes (or one spouse might get a credit for paying those expenses). Deferred sales can be useful to avoid uprooting children at a sensitive time. The downside is it keeps the financial ties intact and can lead to disputes over maintenance, what if someone wants to remodel or if the market shifts, etc. It requires clear agreement on who pays for what and when the sale will occur (or conditions triggering a sale). Illinois courts can and do approve such agreements if mutually desired, but they generally won’t order a deferred sale unless the parties agree, because it’s problematic to force continued co-ownership.

Can a court force the sale of the home during the divorce (before final judgment)? Generally, Illinois courts are reluctant to do so except in special circumstances. Under §501 of the IMDMA (temporary relief), a judge can issue temporary orders to preserve assets. A recent controlling case, In re Marriage of Gabrys, 2023 IL App (1st) 221763, addressed this issue. In Gabrys, the trial court had ordered the immediate sale of the marital residence before the divorce was finished, because the wife had been out of the country for a time and the husband argued she wasn’t really using the home. The wife appealed, and the Appellate Court reversed that order. The court held that an early sale was “wholly unnecessary” and inappropriate – a temporary order should not compel the permanent loss of a unique asset like a home unless truly needed. They referenced that §501 allows temporary relief to maintain the status quo, not to dispose of property, absent “aggravating circumstances” such as an imminent foreclosure or waste of the asset. In other words, you can’t force your spouse to sell the house during the case just because you want your equity out, or because you moved out – only if, say, the house is about to be lost (foreclosure) or neither can afford to keep it and debts are piling up might a sale be ordered to prevent harm. Even then, it’s rare. Illinois courts usually aim to preserve assets until final division. So if one spouse tries a motion for sale, expect the judge to ask: is this absolutely necessary to prevent a financial disaster? If not, they’ll likely deny it and address the home at the final hearing or encourage the parties to agree on a plan.

Case in point: In Roman-Kroczek, 2021 IL App (1st) 210613, a husband had also sought to force a sale of the residence pendente lite. The appellate court in that case similarly noted that selling a marital home is not “temporary” relief because you’re permanently altering the asset. Such a drastic step is only allowed to maintain the financial status quo (for example, selling a home to avoid foreclosure and putting the proceeds in escrow would maintain value, whereas letting it foreclose would destroy value). The guiding principle: courts strive to keep the financial status quo during divorce, not upset it. That often means one spouse may live in the home and the other might get a temporary interest in personal property or compensation, but the asset itself (the house) remains unsold until the final agreement or judgment says otherwise.

Chicago-area considerations: In Cook County (Chicago), the courts also have a general policy (as everywhere) of not removing a spouse from the marital home during the divorce unless there’s a serious reason (like domestic violence – via an Order of Protection or exclusive possession order). So typically, both spouses have equal right to the residence until the divorce is resolved, even if it’s uncomfortable. One might voluntarily move out, but you can’t kick the other out just because you filed for divorce, absent a court order for cause. This affects strategy: sometimes the spouse who wants to keep the house will stay living there, which can strengthen their case later to be awarded it (especially if children are with them and it’s the school residence). However, that spouse also needs to be able to handle the carrying costs during the case or via temporary relief (Illinois courts can order temporary allocation of expenses, e.g. who pays the mortgage during the proceedings).

When it comes to other real estate like vacation homes or rental properties, similar buyout vs. sale decisions apply. Investment properties also introduce the question of capital gains taxes upon sale. A couple might own a lake cabin that has greatly appreciated. If they sell it as part of divorce, there could be capital gains tax (as it’s not a primary residence eligible for the $250k/$500k exclusion). Often, one spouse might take the rental property and the other take more cash assets, to defer taxes (the spouse taking it may plan to 1031-exchange it or keep it). These tax aspects should be considered so that a 50/50 division doesn’t accidentally turn into 60/40 post-tax. We’ll touch on real estate tax implications in the tax section.

In summary, for the marital home the three main routes each have trade-offs:

Illinois judges will approve any of these if the parties agree it’s in their best interest. If left to the judge, they will consider the factors like children’s needs, each party’s finances, etc. Often, judges try to allow the parent with primary custody to keep kids in the home if financially feasible (especially if close to finishing school, etc.), but not at the expense of absolute inequity. For example, a court might award the home to Wife but give Husband more of other assets or a lien on the home’s equity if there’s a huge imbalance. Creativity and practicality are important – and that’s where attorneys will negotiate a tailored solution.

Hidden Assets and Forensic Accounting: Uncovering the Truth

A major concern in many divorces – especially high-net-worth ones – is the possibility that one spouse is hiding assets or not fully disclosing finances. Illinois law requires full financial disclosure; failing to do so can result in reopened cases (as in Brubaker above) and sanctions. Still, if a spouse is determined to cheat, they might attempt to conceal assets in various ways. This is where forensic accounting comes in. Forensic accountants are financial detectives who comb through records to find inconsistencies, undisclosed accounts, and money that “went missing.” Let’s discuss common tactics for hiding assets, red flags to watch for, and tools to expose the truth.

Common ways assets may be hidden:

Red flags of hidden assets: Both attorneys and forensic accountants are trained to spot signs of deception. Here are some warning signs that may indicate assets are being concealed:

Forensic accounting tools: A forensic accountant will use a variety of methods to uncover hidden assets:

Legal remedies for hidden assets: If you find that your spouse has hidden assets, Illinois courts can respond strongly. The court can award the asset (or its value) entirely to the innocent spouse as a sanction. In egregious cases, hiding assets can be considered fraud on the court, potentially opening up a judgment for reversal as we saw in Brubaker (2022). Additionally, if a spouse lies in a financial affidavit, they could be held in contempt or even face perjury charges. Financially, the court can order them to pay the other side’s attorney and forensic accountant fees incurred to uncover the truth. It never pays to hide assets in the long run.

Practically, if you suspect hidden assets:

Forensic red flag example: Suppose during the divorce you notice your spouse’s business, which used to deposit $50,000 monthly, is now only depositing $20,000 monthly into the known account. A forensic accountant might look at the business invoices and see sales are actually steady – meaning $30,000/month is going somewhere else. Indeed, they might discover a new bank account was opened in the business’s name at a different bank. This evidence would be presented, and the court could compel full disclosure of that account and include it in the marital estate. The spouse’s credibility takes a hit, and the court may award a larger share of assets to you or order them to pay fees for the trouble caused.

In summary, hidden assets can be found with diligence and the right expertise. Illinois provides mechanisms to address them once found. As a spouse, keep your eyes open for the red flags discussed (sudden secrecy, money movements, etc.) and advocate aggressively for transparency. A fair outcome is only possible with all cards on the table.

High-Net-Worth Divorce Strategies and Asset Protection

Divorces involving high-net-worth individuals (> $500k net worth, often far more) present unique complexities and opportunities for strategic planning. These cases often include businesses, real estate holdings, complex investment portfolios, trusts, and significant income streams. Mistakes can be very costly when there’s more at stake, so both asset protection and savvy negotiation are paramount. Here we discuss strategic considerations for different scenarios – business owners, executives/employees with complex compensation, and retirees – as well as general tips for those with substantial assets.

For Business Owners: If you own a business, one key goal is usually to retain control of the business after divorce. To do so, you might be willing to give up other assets to “buy out” your spouse’s interest. Start by getting a realistic valuation of the business (as covered earlier). Be transparent but also advocate for a fair (not inflated) valuation – sometimes spouses unrealistically overvalue a business thinking it’s a gold mine, when it may not be so liquid or profitable. You may need to hire your own valuation expert to counter this. Consider how to structure a buyout: if you don’t have enough liquid assets to give your spouse their share, you can negotiate a property settlement note (a promissory note payable over time, say 5 or 10 years, possibly with interest) to pay them gradually. This can be risky if business fortunes decline, but it’s an option.

Be mindful of double dipping: ensure that if you’re going to pay your spouse a portion of business value, that same income isn’t also counted again for spousal support excessively. Illinois courts generally understand not to “double count” the same income stream for both property and maintenance. For example, if your business profits are used to value the business and you give a big chunk to your spouse, you might argue for lower maintenance since they’re effectively getting part of the income via the property division. Conversely, if a large ongoing maintenance is awarded, you might negotiate a lower share of business equity to them. It’s a balancing act.

Asset protection mechanisms such as trusts or holding companies, if set up before the marriage or well before divorce, might shield some assets (for instance, if the business or its real estate is owned by a trust). But courts will look at whether such structures are genuine or just alter egos. If you foresee marriage while owning a business, a prenup is the best protection (e.g. stating the business is separate property and how its value appreciation will be handled). If no prenup, during marriage it’s harder to shield the business except by maintaining clear separation of marital funds (not putting spouse on as co-owner, not using marital funds for it without tracking as loans, paying yourself a reasonable salary so you’re not retaining all earnings in the business which could inflate the divisible value). In some cases, establishing defined benefit plans or deferred comp for yourself can legitimately reduce current business value by turning it into a separate retirement asset (but that’s complex and must be genuine business purpose).

Also, think about client/patient impacts if a professional practice: divorce proceedings can involve appraising client lists or goodwill, which might require revealing financials. Consider confidentiality agreements to protect business info during discovery. Illinois courts can seal records in sensitive business matters or trade secrets if needed.

For High-Earning Employees/Executives: If you are a corporate executive or high-level employee, you might have bonuses, stock options, and other deferred comp. A strategy is to negotiate the trade-off between property division and support. For instance, you might give a bit more cash or assets upfront to avoid a long tail of maintenance (especially since maintenance is no longer tax-deductible to you post-2019). If a large part of your compensation is bonuses or stock that varies year to year, consider an agreement that handles those explicitly (maybe you agree to split actual bonuses for a year or two while divorce is pending or as part of support, rather than trying to predict them). Clarity on those points avoids future disputes.

If you receive restricted stock or options regularly, an important protective measure is ensuring that any settlement agreement specifies how future grants will be treated. Typically, only grants up to the divorce are marital, but sometimes litigating later whether a bonus received just after divorce was for past work during marriage or future work can cause conflict. You may negotiate an arrangement for any expected near-term payouts. Executives also often have perks like deferred comp accounts, supplemental retirement plans, etc. Don’t overlook those in disclosure (or as the non-employee spouse, ensure they’re accounted for).

Asset protection for individuals might include maxing out contributions to things like retirement accounts and HSAs (which are then non-taxable and eventually divided but at least you’ve sheltered income). It could also involve investing in exempt assets – for example, in some states things like annuities or life insurance cash value have creditor protections (though that doesn’t stop division in divorce, it’s more for creditors). In Illinois, there’s no blanket exemption that would remove an asset from the marital pool, so the focus is on lawful, sensible financial management rather than trying to hide money.

For Retirees or Near-Retirees: Divorce after retirement (or near it) means there’s little opportunity to rebuild wealth, so the stakes are high. A key strategy is to carefully plan the division to ensure both parties can meet their post-divorce living expenses. This often means focusing on income-producing assets or secure income streams. A pensioner might agree to give more of a 401(k) in exchange for keeping full pension income, or vice versa, depending on needs and life expectancy. Social Security benefits are not divisible in divorce, but a lower-earning spouse may be entitled to derivative benefits on the higher earner’s record (which doesn’t affect the higher earner’s payments). Attorneys should factor in the reality that two households cost more to run than one, and a just division might not be equal if one spouse truly has much greater need and less ability to ever earn again.

Retirees should also consider health care coverage – after divorce, a younger spouse might lose coverage under the older spouse’s retiree medical plan, for example. That could be raised as part of negotiations (perhaps an asset trade to offset the cost of acquiring health insurance).

Another consideration: Required Minimum Distributions (RMDs) from IRAs after a certain age. If dividing an IRA, each will have their own RMDs. The plan for accessing retirement funds should be tax-efficient. Sometimes, one spouse keeping a Roth IRA and the other a Traditional IRA might be equitable in value today, but very different in after-tax value. So high-net-worth couples might get into the weeds of “equalizing” the division on an after-tax basis. This requires financial expertise but can be important for fairness.

Trusts and asset protection vehicles: Wealthy individuals often have trusts either set up by themselves or by family (e.g., inherited wealth in a trust). If a trust is truly separate (established by a third party for one spouse, and that spouse has no control over it, just a beneficiary), it is likely non-marital property. But sometimes a spouse creates a trust during marriage – depending on the terms, it could be considered a fraudulent transfer if it was meant to shield assets from the other spouse. Illinois courts can invalidate transfers to a trust if done to defeat marital rights (especially if done after divorce was imminent). However, legitimate estate planning trusts made during marriage that both parties were aware of can be more nuanced. High-net-worth cases often involve tracing money flows through various accounts and entities. This is another area where forensic accounting and expert testimony might be needed, say, to determine if funds in an offshore trust were marital before being transferred.

One powerful tool in Illinois for high-net-worth cases is mediation or collaborative divorce with financial neutrals. Instead of a scorched-earth litigation, spouses might jointly hire a neutral financial expert to propose win-win divisions (considering tax and growth). This can preserve more wealth (by avoiding high legal fees and destructive public fights that can even impact business goodwill). It’s something to consider – keeping the matter private and amicable can be an “asset” in itself, especially for public figures or business owners who don’t want dirty laundry out (Illinois divorce filings are public, but financial info can sometimes be kept confidential or minimal if settled out of court).

In summary, high-net-worth divorces require careful, individualized planning. Business owners should aim to retain their companies and offset their spouse fairly, while mitigating double-dip issues. Executives should parse out complicated pay packages in the settlement to avoid future entanglements and ensure nothing is overlooked. Retirees should focus on income and security, making sure the division accounts for longevity and health costs. Across the board, using experienced financial advisors, considering tax ramifications at every step, and if possible, having had prenuptial agreements or other pre-planning will make a big difference. Where no prenup exists, the strategies shift to smart negotiation: perhaps trading a larger immediate asset share to one spouse in exchange for no maintenance, or vice versa, depending on what each values. Protecting assets isn’t about hiding them – it’s about structuring the division and post-divorce finances so that each party’s core needs are met and no unnecessary value is destroyed in the process.

Tax Implications of Property Settlements (2024–2025)

An often overlooked aspect of property division is the tax impact. A settlement that looks equal on paper may not be equal after taxes. Unlike alimony (maintenance) which historically had tax effects (deductible to payor, taxable to payee pre-2019; now not deductible or taxable for divorces after 2018), property settlements generally do not trigger immediate income tax because of IRC §1041. That section provides that transfers of property “incident to divorce” are tax-free – meaning no recognition of capital gains or losses on the transfer, and the receiving spouse takes the original cost basis. But future taxes still loom: when the receiving spouse eventually sells an asset, they’ll pay any gains. So parties and courts try to account for major differences in asset “tax footing.” Here are key tax considerations in Illinois divorces for 2024–2025:

It’s often advisable for high-asset cases to involve a tax professional or CDFA (Certified Divorce Financial Analyst) to model the after-tax results of various settlement scenarios. This helps avoid nasty surprises later. For instance, a CDFA can produce a report showing: if Spouse A gets these assets and Spouse B gets those, here’s what each will pay in taxes over the next X years and what net cash flow they have for retirement, etc. This can guide a more equitable arrangement that a court would likely approve as well.

Example to illustrate: Jack and Diane are divorcing. Jack will be in a high tax bracket post-divorce, Diane in a moderate bracket. They have $1 million in a taxable investment account with a $600k basis (so $400k gain), and a $1 million IRA (pre-tax). Splitting each 50/50: each gets $500k of IRA and $500k of the investments. If each sells their $500k investments, each has $200k gain – Jack pays ~30% tax (combined federal/state) on that $200k = $60k, net $440k; Diane pays ~20% = $40k, net $460k. With the IRA, each will pay tax on distributions at their own rates too. An alternative might be: Jack takes $1M of the taxable investments, Diane takes $1M of the IRA. On paper equal, but Jack would shoulder the entire $120k tax if he liquidates, whereas Diane’s IRA withdrawals maybe taxed lower over time, and also she has the option to do conversions, etc. This might actually favor Diane. To be fair, they could adjust by maybe giving Jack $1.1M of the investments for Diane’s $900k of the IRA, or some such tweak. The point is, taxes change the effective value of assets. In negotiations, each asset can be categorized as pre-tax, post-tax, or tax-deferred and adjustments can be made accordingly.

In Illinois, judges typically do not calculate these tax effects for the parties (they’ll divide on gross value unless evidence is presented about a specific tax consequence). It’s on the parties (through attorneys and experts) to raise such issues. However, one of the statutory factors is the “tax consequences of the property division”, so the court can consider it if significant. If, say, one spouse is to receive a portfolio full of stocks with huge gains, an argument can be made that their share is effectively worth less than face value and the court might award them somewhat more to compensate. This argument tends to be more persuasive for one-time inherent gains (like a stock or a piece of real estate) than for something like an IRA which any recipient would have to pay tax on eventually. For retirement accounts, usually each keeps their own tax liability. But for disparate assets, attorneys often factor it into settlements even if courts might not explicitly in a judgment.

2024–2025 specific tax notes: The individual tax rates and brackets in 2025 are set to potentially change if the TCJA provisions sunset (we might see rates go up slightly or brackets shift in 2026). But for now, the capital gains tax top rate remains 20% (plus 3.8% NIIT possibly) federally, and Illinois has a flat 4.95% income tax (capital gains are taxed as ordinary income at 4.95% in IL). So combined top capital gains rate for an Illinois high earner is ~28.8%. This is important for selling appreciated assets. Also note, if a spouse is keeping an investment property and may sell it after divorce, they might use a 1031 exchange to defer taxes – if that’s their plan, they might argue to not discount the value for taxes since they don’t intend to trigger them. So context matters.

Lastly, be aware of property tax implications: The division of real estate should specify who is responsible for property taxes up to the date of transfer or sale. In Illinois, property taxes are paid in arrears (this year’s bill is for last year’s taxes), so divorcing parties often prorate the taxes. Not dividing an asset per se, but could be a significant expense to negotiate (especially with high Cook County taxes). Also, if one spouse keeps the house, any future property tax and mortgage interest deductions will be solely theirs, which might marginally affect their net cost of living (though with the SALT deduction cap at $10k currently, many in high-tax areas aren’t fully deducting property taxes anyway).

In sum, taxes are a critical overlay on property division. A truly equitable division is one that, to the extent possible, equalizes the after-tax position of the parties given the assets each receives. Addressing tax issues upfront in the settlement can prevent disputes and imbalances later. Always consult with a tax professional if there’s anything beyond a very simple asset picture, because a divorce is already financially impactful – there’s no need to tip the scales further due to preventable tax inefficiencies.

Prenuptial and Postnuptial Agreements in Illinois

One of the strongest forms of asset protection in divorce is a well-crafted prenuptial or postnuptial agreement. These agreements allow couples to set their own rules for property division (and sometimes spousal support) in the event of divorce, rather than defaulting to Illinois equitable distribution law. Illinois has adopted the Illinois Uniform Premarital Agreement Act (750 ILCS 10/1 et seq.) which governs prenups. Postnuptial agreements (made after marriage) are generally enforceable in Illinois as well, though they are scrutinized similarly to prenups for fairness and voluntary execution. Here’s what you need to know about prenups/postnups and how they play out in divorce:

What a prenup can do: A prenup can classify property and debts as non-marital, even if acquired during the marriage, alter or eliminate spousal maintenance, and protect family inheritances or business interests. For example, a prenup might state that “each party’s retirement accounts remain their sole property” or “the appreciation of Husband’s premarital business shall remain non-marital.” It can also set a specific division (e.g. spouse gets X dollars after Y years of marriage). Illinois allows broad freedom in prenups as long as they don’t violate public policy (e.g., you can’t predetermine child support or custody in a binding way, and you can’t make someone penniless and dependent on the state).

Enforceability standards: Under Illinois law, a premarital agreement must be in writing and signed by both parties to be enforceable. It becomes effective upon marriage. There are a few grounds on which a prenup can be challenged:

Illinois case law on prenups is relatively supportive of enforcing them, provided the above criteria are met. For example, if both parties had attorneys and the terms were reasonable at the time (even if one ends up regretting it), it will likely stand.

Recent case example – postnup enforcement: In re Marriage of Prill, 2021 IL App (1st) 200516 (a postnuptial agreement case) illustrates how courts analyze these agreements. In Prill, the wife signed a postnup after an unhappy marriage where the husband (a CPA) proposed terms very favorable to him. She received about 13.5% of the marital estate under the deal (about $3.8M value total), and waived maintenance. She later challenged the postnup as unconscionable and signed under duress. The appellate court upheld the postnuptial agreement, finding that while the division was very unequal, the wife understood what she was signing and wasn’t under legally cognizable duress despite claims of emotional pressure. Two of the three judges believed the wife wasn’t coerced to the level that invalidates a contract, and that wanting to “get out of the marriage” fast was her choice. This case shows Illinois courts will enforce even harsh agreements if the basic requirements (voluntariness, disclosure) are met. Dissenting voices may find such results unfair, but the law gives considerable weight to freedom of contract in marriage agreements.

That said, if a prenup or postnup leaves one spouse destitute, courts might refuse to enforce parts of it. For instance, Illinois law (750 ILCS 10/7) provides that if a provision regarding spousal support causes one party undue hardship in light of circumstances not anticipated when the agreement was signed, a court can require some support despite the agreement. So there’s a safety valve.

Practical tips for prenups/postnups:

If you’re already married and didn’t get a prenup, a postnuptial agreement can be executed. Illinois will generally treat it like any contract – but because spouses owe fiduciary duties to each other, courts examine postnups for fairness even more stringently. You can’t exploit a confidence or dominate a weaker spouse into a postnup without risking it being thrown out. A recent Illinois appellate case (In re Marriage of Stoker, 2021 IL App (5th) 200301) for instance addressed a postnup and unconscionability – I won’t dive into specifics, but suffice to say the same principles apply: voluntary, informed, fair disclosure.

Enforcing a prenup or postnup in a divorce means the court will essentially take the agreement’s terms as given for property division (and maintenance if covered). You should ensure your attorney raises the agreement early in the process and perhaps even ask the court for a bifurcated hearing to confirm its validity (sometimes courts decide upfront whether the agreement is valid rather than go through full equitable distribution). If the agreement is upheld, the property division will follow it. If certain issues aren’t covered by it, the court will apply regular law to those. For example, a prenup might list certain assets to remain separate but say nothing about how to divide the marital home – then the marital home gets divided per normal rules.

From the vantage point of someone going through divorce with a prenup in place: Gather the original signed document and any amendments. Make sure it’s not expired or superseded. And be prepared for your spouse to potentially challenge it; discuss with your lawyer the likelihood of it holding up given the circumstances of signing. Often, these challenges can be negotiated – e.g., perhaps the economically disadvantaged spouse agrees not to fight the prenup in exchange for slightly better terms than the strict agreement provides, to avoid legal uncertainty and cost. That ends up almost like renegotiating the financial settlement under the shadow of the prenup’s likely enforceability.

In summary, prenups and postnups, when done properly, are usually enforced in Illinois. They provide predictability – protecting businesses, family wealth, or just simplifying divorce. But they are not bulletproof if obtained unfairly. And they cannot bind issues of child support or child custody. Also note, estate rights: a prenup can also waive estate rights (like the surviving spouse’s right to a percentage of the estate), which is separate from divorce but worth noting as part of asset protection and estate planning.

Common Mistakes to Avoid in Property Division (and Their Costly Consequences)

Divorce is complex, and missteps in dividing property can cost you dearly – sometimes tens of thousands of dollars or more. Here are some frequent mistakes people make in Illinois property division, along with the potential price tag attached and how to avoid them:

One real-world example of costly spite: A couple spent over $100,000 in legal fees fighting over a collection of antiques. Each was convinced the other was hiding one or two pieces and engaged experts and motions galore. In the end, the antiques were divided, each maybe worth $50k total. They essentially spent double their value to do it. The “cost” of that mistake – letting mistrust drive excessive litigation – was enormous, and both walked away financially bloodied. Don’t let that be you. Use mediation if necessary to bridge emotional divides. Every dollar spent on fighting is a dollar less for the pot of assets you’re dividing.

Finally, after the divorce, a mistake is failing to update estate plans and account titles. If you don’t change beneficiaries on life insurance or retirement accounts, your ex could still get those if you die (Illinois law does nullify ex-spouse beneficiary designations for life insurance by statute unless reaffirmed, but it’s not foolproof for all accounts). The cost here could be your intended heirs losing out. So, as part of the “exit plan,” update wills, trusts, account beneficiaries, and property titles (for example, if you owned a house jointly and you got it in the divorce, ensure the deed is solely in your name so that your estate plan, not joint tenancy law, controls its succession).

In summary, avoidable mistakes often come down to: get professional advice on finances and taxes, do thorough discovery, keep emotions in check, and diligently implement the settlement terms. The more informed and rational you can remain, the more of your assets you’ll keep in your pocket rather than lost to taxes, penalties, or legal waste.

Chicago-Specific Considerations (Cook County Practice)

Divorce law in Illinois is statewide, but practicing in Chicago (Cook County) or the surrounding collar counties can have its own flavor and procedural nuances. Cook County’s Domestic Relations Division is one of the busiest in the country, which means a few things for property division cases:

Example – Cook County quirk: Local Rule requires that the marital settlement agreement (or judgment) include certain language if maintenance is non-modifiable or if you’re waiving maintenance, etc. Cook judges will check that. Also, they often require that documents like quitclaim deeds, QDROs, etc., be presented or indicated as agreed to be prepared. They don’t want loose ends. If a judge sees a settlement where, say, one party is keeping a house but no mention of how the other is being removed from the mortgage, the judge might ask on record, “Counsel, how is the refinance being handled? What’s the timeframe?” They sometimes incorporate that into the order (like giving 90 days to refinance or else house must be sold). So be prepared to address such practicalities – judges in Chicago have seen too many cases fall apart post-decree because something wasn’t clear. They may retain jurisdiction to enforce property division, or set status calls to ensure compliance on things like QDROs.

In high-net-worth cases in Chicago, there’s also the possibility of private judges or arbitration if parties agree, for confidentiality. Cook County allows bifurcated proceedings and referrals to private judging by agreement. This isn’t common, but some very wealthy or public couples do this to keep details out of the public court record. It costs more (you’re essentially hiring a retired judge), but it’s an option. If privacy is a major concern (perhaps you have sensitive business trade secrets), discuss with your attorney whether a private adjudication or sealing of records is feasible. Illinois generally keeps divorce financial information private to an extent (the financial affidavit and discovery are not public, just the final judgment is, and one can sometimes file that without schedules). But in open court, things could be said. Cook County does allow requests to close the courtroom for certain testimony (rarely granted, only in extreme cases like proprietary business info). Just be aware of how these matters play out if that is relevant to you.

Finally, remember that Chicago has a high cost of living, and that can indirectly influence things. For example, the value of real estate might be high, but also the cost of replacing that real estate (buying a new house) is high. A judge who lives in the area knows that giving a spouse $200k might not be enough to buy a condo if they lose the house. While they can’t create money, they understand local economic realities. So arguments framed in terms of realistic needs – “If Wife doesn’t keep the home, she will have to spend $X for similar housing in this market” – resonate as long as backed by evidence (like market comparables). It’s not a legal factor per se beyond “needs of the parties,” but tailoring your presentation to local conditions (e.g., property taxes in Cook are significant – if one person keeps the house, that’s a big yearly expense the court might factor into their ability to pay other things) is smart.

In summary, while the law is uniform across Illinois, practicing in Cook County comes with rigorous disclosure requirements and judges who manage heavy caseloads by encouraging fair, efficient settlements. Being organized, reasonable, and conscious of local procedures will serve you well. Leverage the local rules (like mandatory disclosures) to your advantage by being thorough, and avoid frustrating the court with pettiness given their volume. The ultimate goal – whether in Chicago or elsewhere – is an equitable division of property, but understanding the process in your jurisdiction helps you get there with less cost and drama.

Sources:

Illinois Marriage and Dissolution of Marriage Act, 750 ILCS 5/503 (property division factors and definitions); 750 ILCS 5/501 (temporary relief); 750 ILCS 10/1 et seq. (Uniform Premarital Agreement Act). Recent Illinois cases: In re Marriage of Rozdolsky, 2024 IL App (2d) (business valuation dispute); In re Marriage of Gabrys, 2023 IL App (1st) 221763 (forced sale of home reversed as abuse of discretion); In re Marriage of Brubaker, 2022 IL App (2d) 200160 (fraudulent concealment of asset allowed reopening of judgment); In re Marriage of Prill, 2021 IL App (1st) 200516 (postnuptial agreement upheld, not unconscionable); In re Marriage of Roman-Kroczek, 2021 IL App (1st) 210613 (sale of home pre-divorce only allowed to maintain status quo). Forensic accounting insights; Dissipation definition and rules. Cook County local practices.

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Jonathan D. Steele

Written by Jonathan D. Steele

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