Double Counting Future Business Income in Divorce: When a Business Buyout and Earning Capacity Eliminate the Need for Traditional Spousal Support — In re Marriage of Owen & Brinker (Iowa 2025)

I. Introduction

The Iowa Supreme Court’s decision in In re the Marriage of Jason C. Owen and Alison A. Brinker, No. 24-0830 (Iowa Dec. 12, 2025), squarely addresses a recurring problem in high-asset divorce cases: what happens when one spouse retains a closely held business, the other spouse receives a very large cash equalization payment, and the recipient nonetheless seeks traditional spousal support?

The Court holds that where the property division—including a substantial cash buyout of the spouse’s interest in a profitable business— places the recipient in a position to generate sufficient investment income, together with employment earnings, to maintain the marital standard of living, an award of traditional spousal support is inequitable and unnecessary.

Equally significant, the Court clarifies that the future earning potential of a business cannot be used twice: once in valuing the business for property distribution, and again as a basis for spousal support. Doing so, the Court says, results in a “duplicative award” and impermissible “double counting” of the same future income stream.

At stake in Owen & Brinker is the proper interaction between (1) equitable property division, particularly in business-owner divorces, and (2) traditional spousal support under Iowa Code § 598.21A(1). The opinion is especially important for:

• High-income, high-asset divorces where one spouse receives a business and the other receives cash;
• The treatment of investment income from large equalization awards in assessing spousal “need” for support;
• Preventing appellate courts from reshaping spousal support awards merely to narrow income disparities between ex-spouses.

II. Summary of the Opinion

Jason Owen and Alison Brinker were married for nineteen years. During the marriage, Jason founded and grew Accu-Steel, a successful closely held company that designs and manufactures fabric-covered steel-framed buildings. Alison, a trained accountant and former CPA, left outside employment, allowed her CPA license to lapse, and ultimately worked in the family business until the divorce.

At trial, the district court:

• Awarded Jason the business (Accu-Steel), the acreage including the marital home and business premises, and two farms, for a net property award of approximately $7.49 million.
• Awarded Alison the lake house (where she was living with the children) and other assets, netting approximately $1.43 million.
• Ordered a cash equalization payment of $3,032,408 from Jason to Alison to roughly equalize marital assets.
• Denied Alison’s request for $13,500 per month in traditional spousal support, finding that her post-decree earning capacity (salary plus investment income) permitted her to maintain the marital standard of living without alimony.

The Iowa Court of Appeals affirmed the property division but modified the decree to award Alison $3,500 per month in traditional spousal support, reasoning that:

• Jason’s future income potential from Accu-Steel greatly exceeded Alison’s earning potential as an accountant; and
• The nearly $140,000 gap between their projected annual incomes was “difficult to reconcile” without some spousal support.

On further review, the Iowa Supreme Court:

• Adopted the Court of Appeals’ analysis on property valuations and allowed that part of the opinion to stand;
• Vacated the Court of Appeals’ modification granting Alison $3,500 per month in traditional spousal support; and
• Affirmed the district court’s complete denial of spousal support.

Key holdings include:

• The future earnings and “ceiling for income growth” of a closely held business are already incorporated into its valuation when an income-based or hybrid valuation approach is used; using those same expectations again to justify spousal support is impermissible double counting.
• Traditional spousal support is not intended to equalize the parties’ incomes but to allow the recipient to maintain a lifestyle “reasonably comparable” to that enjoyed during the marriage, so long as the payor has the ability to fund that standard.
• Where the property division and the recipient’s earning capacity together are sufficient to maintain the marital lifestyle, no traditional spousal support is warranted—even after a lengthy marriage.
• Appellate courts must give “considerable latitude” to the trial court’s spousal support determinations and avoid “undue tinkering” that encourages expensive and marginally productive appeals.

III. Detailed Analysis

A. Factual and Procedural Background

Jason and Alison married in 2003. Jason had just founded Accu-Steel (2001), which by the time of trial had grown into a significant business with eighteen full-time employees, manufacturing fabric-covered steel-framed buildings for agricultural and commercial uses.

Alison held a bachelor’s degree in accounting from the University of Northern Iowa and was working as a CPA when she married Jason. She later joined Accu-Steel full-time in 2006 and allowed her CPA license to lapse in 2009. The couple had two children (born in 2007 and 2009).

During the nineteen-year marriage, the parties accumulated substantial wealth, including:

• The acreage with their home and the Accu-Steel facilities;
• A lake house on Lake Panorama;
• Two farms; and
• Other investments and assets.

In 2022, Jason filed for dissolution. Parenting issues were largely resolved by stipulation; child support was set by the court. The main contested issues were:

• The valuation and distribution of the substantial marital estate; and
• Whether Alison should receive traditional spousal support, and if so in what amount and duration.

After a one-day trial with expert testimony, the district court:

• Adopted a detailed property division, including a large cash equalization payment to Alison of over $3 million;
• Found that Alison had the ability to earn at least $69,000 annually as an accountant, with potential to earn more if she reactivated her CPA license; and
• Calculated that the $3 million-plus cash equalization payment could reasonably yield investment income of roughly $212,269 per year at a 7% rate of return, for a total projected annual income for Alison of approximately $281,269.

Alison’s affidavit of financial status claimed monthly expenses of more than $25,000 (over $300,000 annually), but the district court found several categories inflated or unsupported:

• The sworn figure included mortgage payments on two farms that she did not receive in the property division, inflating claimed expenses by $6,640 per month.
• Claimed entertainment expenses of $2,790 per month were unsupported and inconsistent with testimony that both parties were “fairly frugal.”
• A combined $6,400 per month for car payments, property taxes, maintenance, and professional fees was questioned, given that none of her three vehicles had loans and property taxes on the lake house were about $9,200 per year (less than $800 per month).

Jason credibly testified that their marital lifestyle was not extravagant. The court noted bank statements showing Alison’s actual monthly expenditures averaged approximately $2,600 in 2022 and $3,800 in 2023 (with credit cards paid in full each month), and concluded that her “need is not as great as portrayed.”

The district court therefore held that Alison could be self-supporting at a standard reasonably comparable to the marital lifestyle and denied her claim for traditional spousal support.

On appeal, Alison challenged both property valuations and the denial of spousal support. The Court of Appeals affirmed the valuation and property distribution but awarded her $3,500 per month in traditional spousal support. Both parties sought further review. The Supreme Court:

• Adopted the Court of Appeals’ reasoning on valuation issues and left those portions intact; but
• Reversed the addition of spousal support and reinstated the district court’s denial.

B. Legal Framework for Spousal Support in Iowa

1. Statutory Criteria: Iowa Code § 598.21A(1)

Iowa Code § 598.21A(1) authorizes spousal support (“maintenance”) “for a limited or indefinite length of time” after considering ten statutory factors, including:

• The length of the marriage;
• The age and health of the parties;
• The distribution of marital property under § 598.21;
• The educational level of each party;
• The earning capacity of the party seeking support;
• The feasibility of that party becoming self-supporting at a standard of living reasonably comparable to that enjoyed during the marriage, and the time needed to achieve this;
• Tax consequences; and
• Any other relevant factors.

Notably, the statute provides that a court may grant spousal support; it is not automatic, even after a long marriage. The length of the marriage is one factor among many, not a trigger for entitlement.

2. Traditional Spousal Support

The type of alimony at issue here is “traditional” (or “permanent”) spousal support. Prior cases describe traditional support as appropriate in long-term marriages where “life patterns have been largely set,” and its purpose is:

Traditional spousal support is “primarily predicated on need and ability”:

• Need — assessed by whether the spouse can be self-supporting at a standard of living “reasonably comparable” to that enjoyed during the marriage, not merely at subsistence level; and
• Ability to pay — whether the payor can satisfy that support obligation while maintaining his or her own standard of living.

Crucially, the standard of “need” is anchored to the parties’ actual pre-divorce lifestyle, not a court-defined minimum:

3. Earning Capacity and Investment Income

Iowa law looks to earning capacity rather than actual current earnings in assessing need for and amount of spousal support. As § 598.21A(1)(e) and cases such as Gust and Mauer make clear, the court must consider:

• Education, training, and skills;
• Work history and experience;
• Time out of the workforce for childcare or other reasons;
• Realistic ability to reenter the market; and
• Critically here, income reasonably expected from assets received in the property division, including investment returns.

In high-asset cases, investment income from distributed property is part of the recipient’s earning capacity for spousal support purposes. The Court reaffirmed this approach by relying heavily on In re Marriage of Mauer, 874 N.W.2d 103 (Iowa 2016).

4. Interrelationship of Property Division and Spousal Support

Spousal support and property division are related but distinct remedies. As the Court in In re Marriage of Probasco, 676 N.W.2d 179, 184 (Iowa 2004), reiterated:

The statutes cross-reference each other:

• § 598.21(5)(h) — property division must consider any spousal support awarded; and
• § 598.21A(1)(c) — spousal support determinations must consider the property distribution.

But the Court emphasizes that the two remedies serve different functions: equitable sharing of marital assets (property) versus ongoing support based on need and ability (alimony). A party cannot ask for both a fair buyout of business equity and ongoing alimony based on the same future profits of that business without creating a double recovery problem.

5. Standard of Review and Deference

Spousal support determinations are reviewed de novo on appeal in Iowa equity cases, but with significant deference to the trial court’s fact-finding and overall sense of equity. The Court cites:

• In re Marriage of Mills, 983 N.W.2d 61, 67 (Iowa 2022) — trial courts are afforded “considerable latitude” and appellate courts intervene only for a “failure to do equity.”
• In re Marriage of Sokol, 985 N.W.2d 177, 182–83 (Iowa 2023) — emphasizing “institutional and pragmatic” reasons to avoid “undue tinkering” with alimony awards, which encourages costly, low-yield appeals.
• In re Marriage of Benson, 545 N.W.2d 252, 257 (Iowa 1996) (en banc) — over-refinement of spousal support invites expensive appeals “wholly disproportionate” to any realistic benefit.

This deference framework is a backdrop to the Court’s conclusion that the district court acted well within its discretion in denying spousal support in this case.

C. Precedents and Authorities Applied

1. In re Marriage of Probasco — Double Counting Future Business Income

Probasco, 676 N.W.2d 179 (Iowa 2004), is the central precedent. There, the husband (Craig) was awarded the parties’ business and related real estate. The wife (Ralane) received a cash payment representing one-half of the current value of those business assets—about $580,250. The district court nonetheless awarded reimbursement alimony on the theory that Craig retained an income-producing asset, while Ralane had only cash.

The Supreme Court reversed, holding that:

Owen & Brinker extends Probasco’s double-counting principle from reimbursement alimony to traditional spousal support. Where the business valuation relies on an income-based or hybrid approach that capitalizes expected future earnings, those future earnings cannot be re-used to justify traditional alimony. Alison’s equalization cash payment already represented her share of future business income; additional support based solely on Jason’s ongoing ability to reap those same earnings would grant her a double share of the same income stream.

2. In re Marriage of Mauer — Needs-Based Calibration and Investment Income

In Mauer, 874 N.W.2d 103 (Iowa 2016), the Court cut a $25,000 monthly traditional alimony award nearly in half, to $12,600. There, the husband (a highly-paid ophthalmologist) could easily pay the larger award, but the Court insisted that the amount be tied to the wife’s need, not simply his wealth.

The Court in Mauer calculated:

• Wife’s reasonable needs: about $208,000 annually;
• Her ability to meet those needs through employment and investments: $57,000 annually;
• Unmet need: $151,000 per year, or around $12,583 per month.

The Court rounded this to $12,600 and emphasized that:

Owen & Brinker explicitly tracks this methodology, but with the critical observation that Alison’s reasonable needs are fully met (and then some) by her own earning capacity: her projected employment income plus investment income from the $3 million cash equalization. Because her “unmet need” is effectively zero, a traditional alimony award is unnecessary, regardless of Jason’s capacity to pay more.

3. In re Marriage of Gust and In re Marriage of Sokol — Purpose and Deference

Gust, 858 N.W.2d 402 (Iowa 2015), and Sokol, 985 N.W.2d 177 (Iowa 2023), frame the core principles:

• Traditional spousal support is designed to allow the recipient to maintain a lifestyle reasonably comparable to that enjoyed during the marriage;
• Duration of marriage is important but not dispositive; even long marriages do not automatically entitle a spouse to traditional support; and
• Trial courts deserve substantial deference in fashioning or denying alimony awards.

In Sokol, the Court warned against appellate “micromanagement” of alimony awards, because such tinkering:

Owen & Brinker deploys these principles to criticize the Court of Appeals’ $3,500 “buffer” award as precisely the sort of post hoc, fine-tuning modification that appellate courts should avoid, especially where the trial court’s analysis of need and ability is well-supported.

4. Other Supporting Cases

• In re Marriage of Anliker, 694 N.W.2d 535 (Iowa 2005), and In re Marriage of Francis, 442 N.W.2d 59 (Iowa 1989) (en banc) — describing traditional alimony as “payable for life or so long as a spouse is incapable of self-support.”
• In re Marriage of Wendell, 581 N.W.2d 197 (Iowa Ct. App. 1998) (en banc) — establishing that traditional alimony is primarily based on need and ability to pay.
• In re Marriage of Sychra, 552 N.W.2d 907 (Iowa Ct. App. 1996) — observing that alimony is justified when a property distribution does not adequately compensate for the economic disadvantages endured during the marriage.
• In re Marriage of Woodward, 426 N.W.2d 668 (Iowa Ct. App. 1988) — underscoring the importance of the payor’s ability to pay in setting alimony.
• In re Marriage of Pazhoor, 971 N.W.2d 530 (Iowa 2022) — confirming that spousal support awards are reviewed de novo while preserving much discretion to the trial court and noting the post-2017 tax treatment of alimony (no deduction to payor, no inclusion in payee’s income).

D. The Court’s Legal Reasoning

1. Calculating Earning Capacities

The district court attributed to Jason an annual income of approximately $420,854, derived from the couple’s tax returns over five years and including Accu-Steel’s pass-through S-corporation profits and farm income. Jason, however, must take on new debt (roughly $3 million) to fund the equalization payment, with substantial interest obligations.

For Alison, the district court found:

• An employment earning capacity of at least $69,000 annually as an accountant; and
• Reasonable investment income of around $212,269 per year from investing the $3 million equalization payment at 7%.

Combined, the court projected Alison’s annual earning capacity at about $281,269.

The Court explicitly approves the use of a reasonable rate of return on a large, liquid cash award when assessing the spouse’s income capacity, consistent with Mauer. Alison criticized the 7% figure as “speculative” but did not advocate a specific alternative rate on appeal, and the Supreme Court notes that—whatever exact rate is appropriate—her overall financial circumstances show she can fully support her prior lifestyle.

2. Assessing “Need” Based on Marital Lifestyle

The Court is careful to tie “need” to the parties’ actual marital standard of living. Alison claimed monthly expenses of just over $25,000 (over $300,000 annually), but the district court found that figure inflated and inconsistent with their actual lifestyle.

After removing non-existent mortgage obligations and questioning other line items, the district court concluded that Alison’s true needs were “not even close” to the $25,000 per month she asserted. Relying on actual bank statement data showing $2,600–$3,800 average monthly spending (including payment of credit card balances in full), the court pegged her realistic monthly need—on Alison’s own corrected numbers—at about $18,518, or $222,216 per year.

The Supreme Court accepts these factual findings as reasonable and within the district court’s prerogative, noting that the trial court was “in the best position to judge the witnesses’ credibility.” On that basis, the Court calculates that Alison has an annual surplus of about $59,053 ($281,269 projected income minus $222,216 in realistic expenses), even if one fully credits her higher-end estimates. This alone strongly undercuts the claimed “need” for traditional support.

3. Rejecting the Court of Appeals’ Income-Gap and “Buffer” Rationales

The Court of Appeals justified its $3,500 monthly award on two main grounds:

1. The variability and risk of the investment income Alison would earn on her cash equalization; and
2. A nearly $140,000 gap between Jason’s and Alison’s projected annual incomes.

The Supreme Court firmly rejects both rationales.

First, as to Alison’s investment risk, the Court reasons that the Court of Appeals improperly attempted to provide “some buffer for poor market years” by imposing a support obligation on Jason. This is inequitable for two reasons:

• It insulates Alison from investment risk while giving Jason no similar protection against business risk, especially given the substantial loan he must take out to fund the equalization payment; and
• It effectively insures Alison against normal investment fluctuations at Jason’s expense, contrary to the purpose of traditional spousal support and inconsistent with Probasco’s recognition that the operating spouse bears the ongoing risk of business performance.

Second, regarding the income gap, the Court stresses that the purpose of traditional spousal support is not to equalize incomes. It is to allow the recipient to maintain a comparable lifestyle to that enjoyed during the marriage, if that requires support and if the payor can afford it. As the Court puts it:

Moreover, the Court notes that the bare comparison of Jason’s gross income and Alison’s gross income ignores the interest burden Jason must shoulder on the loan used to pay Alison’s $3 million. Even at a relatively low rate (5%), the annual interest exceeds $150,000, offsetting and effectively erasing the perceived $140,000 income gap. In reality, taking financing costs into account, Jason’s net advantage is far smaller—and may even disappear—than the Court of Appeals assumed.

4. Double Counting Business Income: Application of Probasco

The Court carefully explains how Accu-Steel was valued and why that matters. Both parties’ experts used a hybrid valuation method that relied heavily on an income-based approach. As Alison’s own valuation expert wrote:

An income-based valuation explicitly capitalizes the company’s expected future earnings and cash flows into a present value using discount or capitalization rates. Therefore, the $3 million-plus equalization payment Alison received already embodies her half of Accu-Steel’s expected future profits.

To then say Jason has a higher “ceiling for income growth” from Accu-Steel and therefore owes traditional spousal support would give Alison:

• Half of the present value of future business income (through the cash equalization); plus
• An additional slice of those same future earnings via monthly support payments, premised on the very income expectations that were capitalized into the business value.

The Court labels that result “duplicative” and inconsistent with Probasco.

5. Tax Consequences and Post-2017 Law

The Court also notes that the Court of Appeals failed to consider tax consequences, as required by § 598.21A(1)(g). Since the federal Tax Cuts and Jobs Act, alimony is no longer deductible to the payor or includible in the payee’s income for divorces finalized after 2018. That means any spousal support paid by Jason would be from after-tax income, and Alison would receive it tax-free.

While not the central basis of the holding, this reinforces the Court’s point that imposing an unnecessary spousal support obligation would further burden Jason’s finances beyond what the bare income figures suggest.

6. The Ultimate Conclusion: No Traditional Support Where There Is No Unmet Need

Synthesizing all these factors, the Court states the new, clear rule:

Alison’s situation fits that template. She:

• Has a robust earning capacity as an accountant (with potential to enhance income by reactivating her CPA license);
• Received over $3 million in liquid assets, capable of generating substantial investment income;
• Was found by the trial court to have significantly overstated her monthly expenses; and
• Can meet or exceed the marital standard of living on her own resources.

Thus, the district court’s denial of spousal support was not only within its “considerable latitude” but the legally correct outcome given Iowa’s need-and-ability framework and Probasco’s limits on double counting business income.

E. Impact and Future Implications

1. High-Asset, Closely Held Business Divorces

The most immediate impact of Owen & Brinker will be felt in divorces involving closely held businesses where:

• One spouse remains in control of the business; and
• The other spouse receives a large cash (or liquid) equalization payment representing a share of business value.

The decision signals that Iowa courts will increasingly favor a “clean break” approach in such cases: once the non-operating spouse receives a fair cash buyout of business value that, together with reasonable employment income, allows maintenance of the marital lifestyle, there is typically no basis for traditional spousal support.

This has several practical consequences:

• Business-owning spouses can argue, with strong support from this case, that a large equalization payment funded by debt often fully satisfies any equitable claims to future income from the business, leaving no room for ongoing traditional alimony.
• Recipients who receive substantial liquidity will face an uphill battle arguing for long-term traditional support if they have marketable skills and the ability to generate investment income.
• Experts and counsel must be careful in presenting valuation evidence; using an income-based or hybrid method strengthens the argument that future profitability has already been “paid out” through the property division.

2. Reaffirmation That Alimony is Need-Based, Not Income Equalization

The Court’s explicit rejection of income equalization as a valid goal for traditional spousal support may reshape litigation strategies:

• Parties seeking support will need to anchor their arguments in concrete, credible evidence of marital lifestyle and post-divorce expenses, not in percentage comparisons of incomes.
• Wealthy payors can rely on Mauer and Owen & Brinker to argue that high income alone does not justify high or lifelong alimony when the recipient’s realistic needs are smaller and can be partially or fully met by their own earnings and investments.

3. Use of Investment Income and Assumed Rates of Return

By acceptance of a 7% assumed investment return on a large, liquid equalization payment, the Court reinforces that significant property awards are not inert—they are expected to generate income, and that income is counted in spousal support analyses.

Future cases may see:

• More detailed expert testimony on reasonable rates of return, risk, and appropriate asset allocation when courts estimate investment income from property divisions.
• Debates over whether a spouse is obliged (or at least expected) to invest in a reasonably prudent, diversified portfolio as opposed to leaving funds in low-yield vehicles when arguing about “need.”

4. Interest Burdens and Net, Not Gross, Income Comparisons

The Court’s emphasis on Jason’s interest obligations as offsetting his apparent income advantage underscores the importance of looking at each party’s net financial position post-decree:

• Courts should adjust gross incomes for debt service tied to the property division, particularly where one party borrows heavily to fund a cash equalization; and
• Advocates should present clear, concrete evidence of interest expenses and repayment obligations when arguing about relative financial circumstances.

5. Appellate Deference and Deterrence of “Fine-Tuning” Appeals

The Court’s criticism of the Court of Appeals’ modification directly reinforces the principle that appellate courts should not lightly adjust support awards that are within a reasonable range of equity. This tends to:

• Discourage appeals that seek minor increases or decreases in support amounts; and
• Encourage trial counsel to litigate spousal support comprehensively at the district court level, recognizing that major reconfigurations on appeal are unlikely absent clear inequity.

6. Alignment with National Trends

Nationally, there is a discernible trend away from open-ended, lifetime alimony and toward:

• Greater emphasis on self-sufficiency where feasible; and
• Viewing substantial property settlements as part of the support calculus.

Owen & Brinker situates Iowa firmly within that trend—especially for high-asset cases—by mandating that courts:

• Give full weight to the income-generating potential of property distributions; and
• Deny traditional support where a spouse can reasonably maintain the marital lifestyle through property and employment earnings alone.

IV. Complex Concepts Simplified

1. Traditional vs. Other Forms of Spousal Support

• Traditional (permanent) spousal support: Ongoing, often indefinite support meant to allow a spouse, usually after a long marriage, to maintain a lifestyle comparable to the marital standard if they cannot earn enough on their own. The focus is on ongoing need and the other spouse’s ability to pay.
• Rehabilitative support: Shorter-term support to allow a spouse to become self-supporting (e.g., to complete education or training).
• Reimbursement support: Compensates a spouse for specific past contributions (such as supporting the other spouse through professional school).

Owen & Brinker deals only with traditional support.

2. Earning Capacity vs. Actual Earnings

“Earning capacity” looks at what a person could earn, not just what they happen to earn at the moment of trial. Courts consider:

• Education and licenses (even if currently lapsed);
• Past earning history and experience;
• Market demand for their skills; and
• Income that can reasonably be generated from assets (such as cash or investments) received in the divorce.

In this case, Alison’s earning capacity included:

• A realistic salary for an accountant with her background; and
• Investment returns on her very large cash equalization payment.

3. Business Valuation and the Income-Based Approach

When valuing a closely held business in divorce, experts often use:

• Income-based approach: Estimates the business’s future earnings or cash flows and converts that stream into a present lump-sum value using a discount or capitalization rate.
• Market-based approach: Compares the business to similar companies that have been sold or valued in the marketplace.
• Hybrid approaches: Blend elements of both income and market methods, as occurred here with Accu-Steel.

Under an income-based approach, if the business is expected to generate, for example, $X per year in owner earnings, those expected future earnings are already “built into” the one-time valuation number used in the property division. Thus, paying the non-owner spouse half that valuation gives them half of the business’s future expected profits in capitalized form.

4. Double Counting in Property Division and Spousal Support

“Double counting” occurs when the same income source is used twice to benefit the same person:

• First, in valuing an asset (e.g., capitalizing expected profits of a business into a buyout price); and
• Second, as justification for ongoing support (e.g., claiming alimony because the other spouse still has those future profits).

In Probasco and now Owen & Brinker, the Iowa Supreme Court says this is inequitable. If a non-operating spouse has already been paid their share of the business’s future earning potential through the property division, they cannot then claim alimony based on those same future earnings simply because the other spouse continues to run the business.

5. Standard of Review: De Novo with “Considerable Latitude”

In equity cases (including divorces), the Iowa Supreme Court reviews the record “de novo,” meaning it can look at the facts afresh. But it simultaneously:

• Gives significant weight to the trial court’s credibility determinations; and
• Disturbs the spousal support decision only if there has been a “failure to do equity.”

This is why the district court’s detailed assessment of Alison’s expenses and marital lifestyle—backed by bank records and testimony—carried such weight. The Supreme Court will not lightly second-guess a trial judge’s careful, fact-intensive call on questions of need and credibility.

6. Marital Standard of Living

“Marital standard of living” is the lifestyle the couple actually lived during the marriage: the level of spending, saving, housing, vacations, vehicles, and general consumption they jointly maintained.

It is not an aspirational or theoretical standard and does not refer to:

• Minimum subsistence standards; or
• What the court thinks the spouses “should” have spent.

In this case, evidence showed that Jason and Alison were “fairly frugal,” and Alison’s historic monthly spending of roughly $2,600–$3,800 strongly informed the court’s conclusion that her claimed $25,000 monthly budget exceeded the true marital standard.

7. Tax Treatment of Spousal Support After 2017

For divorces finalized after December 31, 2018, federal law generally:

• Eliminates the deduction for alimony payments from the payor’s income; and
• Eliminates inclusion of alimony in the payee’s taxable income.

This change makes spousal support more expensive to pay and simplifies tax reporting for the recipient. Courts must consider these tax effects in § 598.21A(1)(g) when determining whether and how much support to award.

V. Conclusion

In re the Marriage of Owen & Brinker is a significant Iowa Supreme Court decision that refines and clarifies the law of traditional spousal support in the context of high-asset divorces involving closely held businesses.

The opinion establishes and reinforces several key principles:

• When a spouse receives a large, liquid property settlement—especially a business-interest buyout— and has sufficient earning capacity to maintain the marital lifestyle, traditional spousal support is not warranted, even after a long marriage.
• Business valuations that use an income-based or hybrid approach already account for future earnings; using those same earnings expectations again to justify a spousal support award is impermissible double counting.
• Traditional spousal support is based on need and ability, not on equalizing incomes. The relevant test is whether the recipient can maintain a lifestyle reasonably comparable to the marital standard with their own earnings and investment income.
• Appellate courts must exercise restraint and avoid fine-tuning spousal support awards absent a clear failure to do equity, particularly where the trial court has thoroughly considered all statutory factors.

By vacating the Court of Appeals’ spousal support modification and affirming the district court’s denial of traditional support, the Iowa Supreme Court sends a clear message: a fair property division that equips both spouses to maintain their prior lifestyle can—and often should—obviate the need for ongoing traditional alimony. This decision will guide future courts, attorneys, and parties in structuring equitable resolutions in complex, high-asset dissolution cases across Iowa.