Despite no seeming fundamental economic differences, there have been occasions where divorce courts in different states have reached different conclusions of value for the same type of business.

For example, the appellate courts in Washington and Colorado were asked to address the value of State Farm insurance agencies operating under the same agreement. In the Colorado case, In Re: Graff 902 P.2d 402 (Colo. Ct. App. 1994), the court ultimately settled on a value for the agency that included goodwill, while a Washington court limited the value of the agency to the hard assets.

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