In the October 31, 2011 opinion in Burch v. Burch, 395 S.C. 318, 717 S.E. 2d 757 (2011), the South Carolina Supreme Court finally ratifies the passive
versus active gain distinction the Court
of Appeals has used for years in determining the
valuation date for marital
assets that change value between the date
of filing and the -LSB-...]