With no explanation, chose the best option from "A", "B", "C" or "D". of husband’s retirement benefits that were community property valued at date of divorce plus future increases other than those attributable to post-divorce elevation in rank or services rendered); Reiss v. Reiss, 40 S.W.3d 605, 611 n. 5 (Tex.App.-Houston [1st Dist.] 2001, pet. denied) (noting that post-divorce cost-of-living increases and interest accruing on nonemployee spouse’s community portion of retirement benefits are subject to community property division); Bloomer v. Bloomer, 927 S.W.2d 118, 121 (Tex.App.Houston [1st Dist.] 1996, writ denied) (op. on reh’g) (awarding nonemployee spouse 50% interest in cost-of-living increases associated with retirement benefits that were community property); Sutherland v. Cobern, 843 S.W.2d 127, 131 (Tex.App.-Texarkana 1992, writ denied) (<HOLDING>); Phillips, 814 S.W.2d at 504 (awarding

A: holding that berry prohibits nonemployee spouse from sharing in any postdivorce increases in value of employees retirement benefits
B: holding that costofliving increases are not the result of any postdivorce labor but rather are a means of offsetting the otherwise declining value of retirement benefits after they become fixed
C: holding that retirement benefit increases due to postdivorce promotion were separate property
D: holding that postdivorce increases in an individuals retirement benefits are subject to community property division if they are not attributable to postdivorce employment or contributions
B.