Following reversal on appeal resulting in retrial, TCT appropriately valued assets at the time of the retrial, not the initial trial. Based on Hayden, TCT has “discretion to set a property valuation date after appeal according to principles of equity based on the facts of the case.” CtA also affirmed TCT’s order to sell real properties instead of valuing them and assigning them to H, in part based on H’s failure to object to court’s proposed statement of decision ordering sale or by demonstrating sale of the properties was not necessary to effect an equal division of community property.

Marriage of Oliverez
3/25/19, CA 6:  H044451
https://www.courts.ca.gov/opinions/documents/H044451.PDF