Second, based on the record that is before us, it appears
that the motion judge significantly misapprehended the parties’
positions on the Guidelines inputs.
 On the question of how much of the pension payout had
already been equalized, the motion judge said that the wife’s
position was that support should be based on an unequalized
pension value of $575,470 (the after-tax value of $843,603 in
2012 minus the after-tax value of $268,133 in 2007). He also
said that the husband’s position was that, at most, the unequalized value of the pension was $321,07216 (the difference between
the after-tax early retirement option and the after-tax age 65
retirement option, as valued in 2007). Neither statement is
 Neither the wife nor Mr. Norton relied on $575,470 as
the unequalized value of the early pension payout that should
be used to determine the quantum of spousal support. Rather,
Mr. Norton developed a ratio as his primary assessment of
the unequalized value of the pension and posited, as an alternative, the amounts of the pre-tax annual payments that
would have represented the unequalized value of the pension
had the husband elected to receive his pension. The wife relied
on those pre-tax alternative values to make her Guidelines
 The husband advocated a maximum pre-tax value of
$469,500 as the unequalized portion of the pension.17 He calculated this figure using pre-tax values from the appendix to the
second DSW report: one-half of the additional value attributable to early retirement plus the value of post-retirement service. Ultimately, the motion judge chose not to rely on the DSW
report. Moreover, he rejected the husband’s argument that the
wife had given up her claim to half of the added value attributable to early retirement based on the terms of the contract.
In this regard, the motion judge noted that while both early
retirement date and age 65 valuations existed when the separation agreement was negotiated, the separation agreement
16 As previously stated, the motion judge referred to a figure of $321, 720,
which is a typographical error.
17 In the husband’s original factums filed on the change motion, dated April
7, 2014 and May 28, 2014, respectively, the husband advocated the position enunciated by the motion judge. However, the change motion was
finally heard several months later, in October 2014 and February 2015,
and the husband did not adopt his factum position in his oral submissions
before the motion judge.