With no explanation, chose the best option from "A", "B", "C" or "D". is presumed in divorce actions. But this presumption is subject to the trial court's broad discretionary powers concerning the division of community property. See id. 6 . Taggart v. Taggart, 552 S.W.2d 422, 424 (Tex.1977) (setting out formula for determining extent of community interest in retirement benefits upon divorce). 7 . At divorce, the trial court found the plans were valued as follows: $58,197 (plan B, above); $92,919 (plan C); $.162,302 (plan D); and $25,652 (plan E). Of these amounts, Ginger received 50%, or: $29,098 (plan B); $46,459 (plan C); $81,151 (plan D); and $12,826 (plan E). 8 . But see Berry, 647 S.W.2d at 947 (rejecting, without analysis, concept of inflation as factor to be considered in determining post-divorce retirement benefits); May, 716 S.W.2d at 711 (<HOLDING>); Dunn v. Dunn, 703 S.W.2d 317, 321

A: holding that berry prohibits nonemployee spouse from sharing in any postdivorce increases in value of employees retirement benefits
B: 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
C: holding that a nonemployee spouse holds a community marital property interest in pension plan early retirement enhancements because practically by definition the right to retirement benefits that accrues at least in part during marriage before separation underlies any right to an enhancement
D: 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
A.