Rule: A business started by the efforts of both spouses during marriage is CP. Application: W and H opened their law firm in 2005, during marriage. Since H brought a number of his biggest clients with him from his previous firm, he will argue that the law practice was built on his goodwill alone and is therefore his SP. W will argue that the law practice is a CP business because it was started and developed by the time, skill, and efforts of both she and H during marriage. Conclusion: Since marital labor of both spouses started and developed the law practice, it is CP and will be divided 50-50