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Tuesday, April 16, 2019  
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In re: Marriage of Begian and Sarajian
Cal.App. 2nd Dist. (B278316) 12/20/18;
pub. order 1/18/19 Case complete 3/20/19

The court held that a "Trust Transfer Deed," signed by a husband, granting real property to his wife, did not meet Family Code section 852(a)'s express declaration requirement in order to transmute property. The document's use of the words "grant" and "gift" were not sufficient alone to satisfy the requirement, because the deed did not unambiguously indicate a change in character or ownership of the property. The court noted that granting the property to the wife "as her sole and separate property" would have satisfied the express declaration requirement.


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