Respondents contend that the trial court did not award punitive damages and did not include them in the written judgment, so the entire issue need not be considered. Peterson v. Peterson, 3 Wn. App. 374, 377, 475 P.2d 576 (1970). While the general rule certainly is that the oral opinions of a court are not subject to challenge unless they have been incorporated into the written findings, application of that principle to allegations of judicial prejudice is problematic since a judge's own statements are typically the only available evidence of prejudice.
While the court considers the nature and extent of the community and separate property, see former RCW 26.09.080 (1973), the character of the property need not be specifically designated or labeled. Peterson v. Peterson, 3 Wn. App. 374, 377, 475 P.2d 576 (1970). Moreover, the court need not characterize each piece of property.
The character of each item need not be specifically designated or labeled. Peterson v. Peterson, 3 Wn.App. 374, 475 P.2d 576 (1970), and the court is not required to specifically characterize each item. In re Marriage of Melville, 11 Wn.App. 879, 526 P.2d 1228 (1974).
As previously stated, the disposition of property upon dissolution is within the court's sound discretion and will not be disturbed unless it is manifestly unreasonable. Peterson v. Peterson, 3 Wn. App. 374, 377-78, 475 P.2d 576 (1970). We will not disturb a property valuation having reasonable support in the trial record.
Trial courts have wide discretion to divide property equitably in dissolution proceedings. Peterson v. Peterson, 3 Wn. App. 374, 475 P.2d 576 (1970). We find no abuse of the court's discretion in this property division.
In making the property division, the court must bear in mind the correct community or separate property status of the property to be divided. If the court does not do so, its division of the property constitutes reversible error. Peterson v. Peterson, 3 Wn. App. 374, 475 P.2d 576 (1970); Fite v. Fite, 3 Wn. App. 726, 479 P.2d 560 (1970); Blood v. Blood, 69 Wn.2d 680, 419 P.2d 1006 (1966). [3] In the instant case, defendant claims she has a community interest in 15 items of property valued at $280,206.
While we might not, in the first instance, have chosen either this method of distribution or the specific distribution made by the trial court, we cannot declare that there has been, under all the circumstances, a manifest abuse of discretion by the trial court. Peterson v. Peterson, 3 Wn. App. 374, 475 P.2d 576 (1970). Judgment is affirmed.
The large disparity in earning capacity of the parties would, in our opinion, justify the award of $160,000 to the defendant of total assets of $604,000. See Peterson v. Peterson, 3 Wn. App. 374, 475 P.2d 576 (1970). Nor do we find an abuse of discretion on the part of the decree requiring plaintiff to pay the obligations of the parties incurred during the marriage, including all tax obligations.