A trial court may use one or more of the above described approaches, as well as any other approach suitable for that case. After all, a degree cannot be sold as such. It has no market value in and of itself. The value is as ephemeral as Bill Gates' brain or Julia Robert's beauty. Both can be used to gain money, but physical asset itself is not transferable.
Professional degrees are only as good as what the holder of the degree chooses to do with it.
That choice then translates into income, which is available as maintenance. To attach a value to an unsaleable entity would negate years of prior case law in Wisconsin which dictates the proper method of valuing property as fair market value . Fair Market Value is the amount a willing buyer would pay a willing seller, both having knowledge of all relevant circumstances and neither under any compulsion to buy or sell. Under this definition, a degree which can only be used to secure future income, has no value. Allowing the court to compensate the contributing spouse in the form of maintenance does not fully resolve the issue, either.