California, United States of America
The following excerpt is from Willis v. State of California, 22 Cal.App.4th 287, 27 Cal.Rptr.2d 413 (Cal. App. 1994):
Plaintiff points to the abolition of the terminable interest rule as support for her position. While we recognize the community property interests of surviving spouses, the terminable interest rule has no application to the issues raised in this appeal. Nor does our 1983 case, Chirmside v. Board of Administration (1983) 143 Cal.App.3d 205, 191 Cal.Rptr. 605, dictate a [22 Cal.App.4th 294] different result. In Chirmside we declined to expand the then existing terminable interest rule to pension plan contributions that only represent withheld earnings during marriage. We wrote:
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