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The court will figure out what percentage of marital income was put into the account. Example: You had $10K and deposited $1k twice for a total of $12k, so $2k is approx. 17%. Also you have to determine what gain was made after the first marital deposit and then after the second and determine a percentage of the gain that was part of the marital estate. If the separate account was joined with a marital account, you do the same calculation to determine what percentage was separate asset and what percentage is marital.