For Joint Title Presumption to be Valid, Family Code § 852 Requirements Must be Met

The trial court determined when the husband added his wife as a partner in a modification of a partnership agreement; it converted the husband’s separate property interest to community property, and ordered the husband to pay the wife’s attorney fees and costs. The husband appealed asserting that his partnership interest was his separate property, regardless of the modification of partnership agreement. The appellate court reversed the trial court’s decision.