section 19-6-15(f) gross income in Georgia

2025Cf. Berg v. Beaver, 364 Ga. App. 350 , 352-53 (1) ( 874 SE2d 868 ) (2022) (explaining that father’s submission of tax returns, bank statements, and other income and expense statements did not preclude trial court from imputing his income when establishing child-support obligation, given that father was unable to explain discrepancies in financial documents, could not explain why certain income was included on some documents but not on others or why deposits into his bank account far exceeded his reported income); Franco, 361 Ga. App. at 509-10 (1) (a) (holding that trial court could impute fat

2022As our Supreme Court has explained, there are two “conditions precedent to” imputing gross income under OCGA § 19-6-15 (f) (4) (B) in cases involving 4 The trial court’s findings were made orally following the hearing, in the Final Order, and in the Order denying Berg’s motion to amend. 5 modification of child support: “(1) a parent’s failure to produce ‘reliable evidence of income’ and (2) the absence of any other reliable evidence of such parent’s income or income potential.” (Citation and punctuation omitted.) Jackson v. Sanders, 299 Ga. 332, 334 ( 788 SE2d 387 ) (2016).5 Although it is tru

2022As our Supreme Court has explained, there are two “conditions precedent to” imputing gross income under OCGA § 19-6-15 (f) (4) (B) in cases involving 4 The trial court’s findings were made orally following the hearing, in the Final Order, and in the Order denying Berg’s motion to amend. 5 modification of child support: “(1) a parent’s failure to produce ‘reliable evidence of income’ and (2) the absence of any other reliable evidence of such parent’s income or income potential.” (Citation and punctuation omitted.) Jackson v. Sanders, 299 Ga. 332, 334 ( 788 SE2d 387 ) (2016).5 Although it is tru

2022As our Supreme Court has explained, there are two “conditions precedent to” imputing gross income under OCGA § 19-6-15 (f) (4) (B) in cases involving 4 The trial court’s findings were made orally following the hearing, in the Final Order, and in the Order denying Berg’s motion to amend. 5 modification of child support: “(1) a parent’s failure to produce ‘reliable evidence of income’ and (2) the absence of any other reliable evidence of such parent’s income or income potential.” (Citation and punctuation omitted.) Jackson v. Sanders, 299 Ga. 332, 334 ( 788 SE2d 387 ) (2016).5 Although it is tru

2025Indeed, absent evidence of Gibson’s present ability to earn $681,820 and ability to pay $9,764 monthly in child support, this “portion of the award cannot stand.”15 Accordingly, we vacate the trial court’s final order of child- support modification and remand the case for the court to engage in a determination of Gibson’s income under OCGA § 19-6-15 (f) (4) (B) and entry of an award that is supported by the evidence. 15 Lockhart v. Lockhart, 361 Ga. App. 499 , 502 (1) (a) ( 863 SE2d 174 ) (2021); see Duncan, 262 Ga. at 874 (2) (reversing trial court’s child-support award purportedly based on f

2025Indeed, absent evidence of Gibson’s present ability to earn $681,820 and ability to pay $9,764 monthly in child support, this “portion of the award cannot stand.”15 Accordingly, we vacate the trial court’s final order of child- support modification and remand the case for the court to engage in a determination of Gibson’s income under OCGA § 19-6-15 (f) (4) (B) and entry of an award that is supported by the evidence. 15 Lockhart v. Lockhart, 361 Ga. App. 499 , 502 (1) (a) ( 863 SE2d 174 ) (2021); see Duncan, 262 Ga. at 874 (2) (reversing trial court’s child-support award purportedly based on f

2025Indeed, absent evidence of Gibson’s present ability to earn $681,820 and ability to pay $9,764 monthly in child support, this “portion of the award cannot stand.”15 Accordingly, we vacate the trial court’s final order of child- support modification and remand the case for the court to engage in a determination of Gibson’s income under OCGA § 19-6-15 (f) (4) (B) and entry of an award that is supported by the evidence. 15 Lockhart v. Lockhart, 361 Ga. App. 499 , 502 (1) (a) ( 863 SE2d 174 ) (2021); see Duncan, 262 Ga. at 874 (2) (reversing trial court’s child-support award purportedly based on f

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015We acknowledge Jackson’s argument that the high-income deviation was impermissible because the trial court erred in calculating his income under OCGA § 19-6-15 (f) (4) (B), but as explained in Division 2 supra, the trial court did not err in that respect. 38 See OCGA § 19-6-15 (o). 39 OCGA § 19-6-15 (i) (2) (A). 40 See id.; see also Henry v. Beacham, 301 Ga. App. 160, 163 (2) (a) ( 686 SE2d 892 ) (2009) (noting that the child-support guidelines list specific examples in which a deviation may be appropriate, including when the parents have a calculated monthly income higher than $30,000, which

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2015In sum, given the lack of evidentiary support for Jackson’s testimony regarding his business’s finances and income from his rental properties; the inaccuracies and omissions in his DRFA; and his seemingly disingenuous testimony that, although he wanted his accountant to testify regarding his finances, he nevertheless told his accountant that such testimony was unnecessary, we simply cannot say that the trial court abused its discretion in finding that Jackson failed to produce reliable evidence of his gross income and thus, calculating his gross income under OCGA § 19-6-15 (f) (4) (B).28 27 Se

2012See Jarvis v. Jarvis, 584 NW2d 84, 90 (III) (N.D. 1998) (disallowing “double credit for the uninsured medical expenses” paid by father); Miller-Bent v. Miller-Bent, 680 So2d 1119,1120-1121 (Fla. App. 1996) (“Giving the husband credit for [the full amount of health-insurance premiums] in two separate calculations constituted error.”).

2010We join those *278 courts which “have rejected outright a double-dipping claim [with respect to] child support, reasoning that as between parent and child, the ... asset subject to property division is not being counted twice. [Cits.]” Steneken v. Steneken, 843 A2d 344, 351 (N.J.