With no explanation, chose the best option from "A", "B", "C" or "D". are subject to equitable division unless it can be shown by proof that such assets are attributable to one of the parties’ separate estates prior to the marriage or outside the marriage. Hemsley v. Hemsley, 639 So.2d 909, 914 (Miss.1994). Frequently a presumption of marital property arises to any property acquired during the marriage. 1 Ann Oldfather, Janice E. Kosel, et al, Valuation and Distribution of Marital Property, § 3.03(4) at 3-37. (1994 ed.). Commingled property is a combination of marital and non-marital property which loses its status as non-marital property as a result. 1 Ann Oldfather, Janice E. Kosel, et al, Valuation and Distribution of Marital Property, § 3.03(5) at 3-37. (1994 ed.). See also Boggs v. Boggs, 26 Ark.App. 188, 761 S.W.2d 956, 957 (1988) (en bane) (<HOLDING>). Kenneth cites the cases of Johnson v.

A: holding that devise of real estate to one spouse was nonmarital and noting that had testator intended such property to be devised as marital property he could have designated appellant as a joint tenant
B: holding that transferring joint property into one partys name for estate planning purposes does not convert marital property into nonmarital property
C: holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property
D: holding money received from inheritance as nonmarital property presumptively became marital property when placed in joint account under arkansas law
D.