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Court hears arguments on tracing and valuation of trust assets on remand in Dahl v. Dahl

Utah Court of Appeals (oral argument, live stream) · January 29, 2026
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Summary

On remand from the Utah Supreme Court, the Court of Appeals heard argument over whether the district court properly identified and valued trust assets for distribution to Kim Dahl, including disputes over commingling, traceability of premarital funds, discovery limits, dissipation claims and whether valuation should use a 2010 date or a post-remand/current valuation.

The Utah Court of Appeals heard oral argument in Dahl v. Dahl (No. 20240740), a remand-focused dispute about what trust property should be characterized as marital property and how it should be valued. Counsel for appellant Kim Dahl, Steve Christensen, said the Supreme Court directed the district court to identify trust assets that should be returned or credited to Ms. Dahl and argued the lower court improperly treated the task as too difficult because of alleged commingling and by restricting post-2010 discovery.

Christensen…

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