With no explanation, chose the best option from "A", "B", "C" or "D". value of community property interest upon divorce, based on Taggart formula); Phillips v. Parrish, 814 S.W.2d 501, 504 (Tex.App.-Houston [1st Dist.] 1991, writ denied) (applying Berry formula); May, 716 S.W.2d at 707 (same). In this case, it is undisputed that all of the property in the defined benefit plans (plans B-E) at th post-divorce increases in benefits that are separate property). But post-divorce cost-of-living increases and other increases in value that are not attributable to the employee’s continued employment after divorce are community property subject to division. See Grier, 731 S.W.2d at 933 (awarding nonemployee wife pe ee spouse her share of post-divorce cost-of-living increases and increases due to upgrading of benefits); see also Burchfield, 968 S.W.2d at 424 (<HOLDING>). Applying these principles to this situation,

A: holding that retirement benefit increases due to postdivorce promotion were separate property
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 railroad retirement benefits are not community property by congressional action
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
D.