2020 Georgia Code
Title 19 - Domestic Relations
Chapter 6 - Alimony and Child Support
Article 1 - General Provisions
§ 19-6-15. Child Support Guidelines for Determining Amount of Award; Continuation of Duty of Support; Duration of Support

1. Definitions. As used in this Code section, the term:
   1. Reserved.
   2. "Adjusted income" means the determination of a parent's monthly income, calculated by deducting from that parent's monthly gross income one-half of the amount of any applicable self-employment taxes being paid by the parent, any preexisting order for current child support which is being paid by the parent, and any theoretical child support order for other qualified children, if allowed by the court. For further reference see paragraph (5) of subsection (f) of this Code section.
   3. "Basic child support obligation" means the monthly amount of support displayed on the child support obligation table which corresponds to the combined adjusted income and the number of children for whom child support is being determined.
   4. Reserved.
   5. Reserved.
   6. "Child support obligation table" means the chart set forth in subsection (o) of this Code section.

      (6.1) "Child support services" means the entity within the Department of Human Services and its contractors that are authorized to enforce a duty of support.

   7. "Combined adjusted income" means the amount of adjusted income of the custodial parent added to the amount of adjusted income of the noncustodial parent.
   8. "Court" means a judge of any court of record or an administrative law judge of the Office of State Administrative Hearings.
   9. "Custodial parent" means the parent with whom the child resides more than 50 percent of the time. When a custodial parent has not been designated or when a child resides with both parents an equal amount of time, the court shall designate the custodial parent as the parent with the lesser support obligation and the other parent as the noncustodial parent. When the child resides equally with both parents and neither parent can be determined as owing a greater amount than the other, the court shall determine which parent to designate as the custodial parent for the purpose of this Code section.
   10. "Deviation" means an increase or decrease from the presumptive amount of child support if the presumed order is rebutted by evidence and the required findings of fact are made by the court or the jury pursuant to subsection (i) of this Code section.
   11. "Final child support amount" means the presumptive amount of child support adjusted by any deviations.
   12. "Gross income" means all income to be included in the calculation of child support as set forth in subsection (f) of this Code section.
   13. "Health insurance" means any general health or medical policy. For further reference see paragraph (2) of subsection (h) of this Code section.
   14. "Noncustodial parent" means the parent with whom the child resides less than 50 percent of the time or the parent who has the greater payment obligation for child support. When the child resides equally with both parents and neither parent can be determined as owing a lesser amount than the other, the court shall determine which parent to designate as the noncustodial parent for the purpose of this Code section.
   15. "Nonparent custodian" means an individual who has been granted legal custody of a child, or an individual who has a legal right to seek, modify, or enforce a child support order.
   16. "Parent" means a person who owes a child a duty of support pursuant to Code Section 19-7-2.
   17. "Parenting time deviation" means a deviation allowed for the noncustodial parent based upon the noncustodial parent's court ordered visitation with the child. For further reference see subsections (g) and (i) of this Code section.
   18. "Preexisting order" means:
       1. An order in another case that requires a parent to make child support payments for another child, which child support the parent is actually paying, as evidenced by documentation as provided in division (f)(5)(B)(iii) of this Code section; and
       2. That the date and time of filing with the clerk of court of the initial order for each such other case is earlier than the date and time of filing with the clerk of court of the initial order in the case immediately before the court, regardless of the age of any child in any of the cases.
   19. "Presumptive amount of child support" means the basic child support obligation including health insurance and work related child care costs.
   20. "Qualified child" or "qualified children" means any child:
       1. For whom the parent is legally responsible and in whose home the child resides;
       2. Who the parent is actually supporting;
       3. Who is not subject to a preexisting order; and
       4. Who is not before the court to set, modify, or enforce support in the case immediately under consideration.

          Qualified children shall not include stepchildren or other minors in the home who the parent has no legal obligation to support.

   21. "Split parenting" can occur in a child support case only if there are two or more children of the same parents, when one parent is the custodial parent for at least one child of the parents, and the other parent is the custodial parent for at least one other child of the parents. In a split parenting case, each parent is the custodial parent of any child spending more than 50 percent of the time with that parent and is the noncustodial parent of any child spending more than 50 percent of the time with the other parent. A split parenting situation shall have two custodial parents and two noncustodial parents, but no child shall have more than one custodial parent or noncustodial parent.
   22. "Theoretical child support order" means a hypothetical child support order for qualified children as calculated in subparagraph (f)(5)(C) of this Code section which allows the court to determine the amount of child support as if a child support order existed.
   23. "Uninsured health care expenses" means a child's uninsured medical expenses including, but not limited to, health insurance copayments, deductibles, and such other costs as are reasonably necessary for orthodontia, dental treatment, asthma treatments, physical therapy, vision care, and any acute or chronic medical or health problem or mental health illness, including counseling and other medical or mental health expenses, that are not covered by insurance. For further reference see paragraph (3) of subsection (h) of this Code section.
   24. "Work related child care costs" means expenses for the care of the child for whom support is being determined which are due to employment of either parent. In an appropriate case, the court may consider the child care costs associated with a parent's job search or the training or education of a parent necessary to obtain a job or enhance earning potential, not to exceed a reasonable time as determined by the court, if the parent proves by a preponderance of the evidence that the job search, job training, or education will benefit the child being supported. The term shall be projected for the next consecutive 12 months and averaged to obtain a monthly amount. For further reference see paragraph (1) of subsection (h) of this Code section.
   25. "Worksheet" or "child support worksheet" means the document used to record information necessary to determine and calculate monthly child support. For further reference see subsection (m) of this Code section.
2. Process of calculating child support. Pursuant to this Code section, the determination of monthly child support shall be calculated as follows:
   1. Determine the monthly gross income of both the custodial parent and the noncustodial parent. Gross income may include imputed income, if applicable. The determination of monthly gross income shall be entered on the Child Support Schedule A - Gross Income;
   2. Adjust each parent's monthly gross income by deducting the following from the parents' monthly gross income and entering it on the Child Support Schedule B - Adjusted Income if any of the following apply:
      1. One-half of the amount of self-employment taxes;
      2. Preexisting orders; and
      3. Theoretical child support order for qualified children, if allowed by the court;
   3. Add each parent's adjusted income together;
   4. Locate the basic child support obligation by referring to the child support obligation table. Using the figure closest to the amount of the combined adjusted income, locate the amount of the basic child support obligation. If the combined adjusted income falls between the amounts shown in the table, then the basic child support obligation shall be based on the income bracket most closely matched to the combined adjusted income. The basic child support obligation amount stated in subsection (o) of this Code section shall be rebuttably presumed to be the appropriate amount of child support to be provided by the custodial parent and the noncustodial parent prior to consideration of health insurance, work related child care costs, and deviations;
   5. Calculate the pro rata share of the basic child support obligation for the custodial parent and the noncustodial parent by dividing the combined adjusted income into each parent's adjusted income to arrive at each parent's pro rata percentage of the basic child support obligation;
   6. Find the adjusted child support obligation amount by adding the additional expenses of the costs of health insurance and work related child care costs, prorating such expenses in accordance with each parent's pro rata share of the obligation and adding such expenses to the pro rata share of the basic child support obligation. The monthly cost of health insurance premiums and work related child care costs shall be entered on the Child Support Schedule D - Additional Expenses. The pro rata share of the monthly basic child support obligation and the pro rata share of the combined additional expenses shall be added together to create the monthly adjusted child support obligation;
   7. Determine the amount of child support for the custodial parent and the noncustodial parent resulting in a monthly sum certain payment due to the custodial parent by assigning or deducting credit for actual payments for health insurance and work related child care costs from the basic child support obligation;
   8. In accordance with subsection (i) of this Code section, deviations subtracted from or added to the presumptive amount of child support shall be applied, if applicable, and if supported by the required findings of fact and application of the best interest of the child standard. The proposed deviations shall be entered on the Child Support Schedule E - Deviations. In the court's or the jury's discretion, deviations may include, but shall not be limited to, the following:
      1. High income;
      2. Low income;
      3. Other health related insurance;
      4. Life insurance;
      5. Child and dependent care tax credit;
      6. Travel expenses;
      7. Alimony;
      8. Mortgage;
      9. Permanency plan or foster care plan;
      10. Extraordinary expenses;
      11. Parenting time; and
      12. Nonspecific deviations;
   9. Any benefits which the child receives under Title II of the federal Social Security Act shall be applied against the final child support amount. The final child support amount for each parent shall be entered on the child support worksheet, together with the information from each of the utilized schedules;
   10. The parents shall allocate the uninsured health care expenses which shall be based on the pro rata responsibility of the parents or as otherwise ordered by the court. Each parent's pro rata responsibility for uninsured health care expenses shall be entered on the child support worksheet;
   11. In a split parenting case, there shall be a separate calculation and final order for each parent; and
   12. When there is more than one child for whom support is being determined, the court shall establish the amount of support and the duration of such support in accordance with subsection (e) of this Code section. When, within two years of a final order being entered, there is a likelihood that a child will become ineligible to receive support, the court may allow for the use of separate worksheets. Separate worksheets shall show the final child support amount to be paid for all such children and the adjusted amount of support to be paid as each child becomes ineligible to receive support during such two-year period. Such worksheets shall be attached to the final order. Such order shall contain findings as required by law. A final order entered pursuant to this paragraph shall not preclude a petition for modification.
3. Applicability and required findings.
   1. The child support guidelines contained in this Code section are a minimum basis for determining the amount of child support and shall apply as a rebuttable presumption in all legal proceedings involving the child support responsibility of a parent. This Code section shall be used when the court enters a temporary or permanent child support order in a contested or noncontested hearing or order in a civil action filed pursuant to Code Section 19-13-4. The rebuttable presumptive amount of child support provided by this Code section may be increased or decreased according to the best interest of the child for whom support is being considered, the circumstances of the parties, the grounds for deviation set forth in subsection (i) of this Code section, and to achieve the state policy of affording to children of unmarried parents, to the extent possible, the same economic standard of living enjoyed by children living in intact families consisting of parents with similar financial means.
   2. The provisions of this Code section shall not apply with respect to any divorce case in which there are no minor children, except to the limited extent authorized by subsection (e) of this Code section. In the final judgment or decree in a divorce case in which there are minor children, or in other cases which are governed by the provisions of this Code section, the court shall:
      1. Specify in what sum certain amount, the duration of such support, and from which parent the child is entitled to permanent support as determined by use of the worksheet or multiple worksheets when there is more than one minor child;
      2. Specify in what manner, how often, to whom, and until when the support shall be paid;
      3. Include a written finding of each parent's gross income as determined by the court or the jury;
      4. Determine whether health insurance for the child involved is reasonably available at a reasonable cost to either parent. If the health insurance is reasonably available at a reasonable cost to the parent, then the court shall order that the child be covered under such health insurance;
      5. Include written findings of fact as to whether one or more of the deviations allowed under this Code section are applicable, and if one or more such deviations are applicable as determined by the court or the jury, the written findings of fact shall further set forth:
         1. The reasons the court or the jury deviated from the presumptive amount of child support;
         2. The amount of child support that would have been required under this Code section if the presumptive amount of child support had not been rebutted; and
         3. A finding that states how the court's or the jury's application of the child support guidelines would be unjust or inappropriate considering the relative ability of each parent to provide support and how the best interest of the child who is subject to the child support determination is served by deviation from the presumptive amount of child support;
      6. Specify the amount of the noncustodial parent's parenting time as set forth in the order of visitation;
      7. Include a written finding regarding the use of benefits received under Title II of the federal Social Security Act in the calculation of the amount of child support; and
      8. Specify the percentage of uninsured health care expenses for which each parent shall be responsible.
   3. When child support is ordered, the party who is required to pay the child support shall not be liable to third persons for necessaries furnished to the child embraced in the judgment or decree.
   4. In all cases, the parties shall submit to the court their worksheets and schedules and the presence or absence of other factors to be considered by the court or the jury pursuant to the provisions of this Code section.
   5. In any case in which the gross income of the custodial parent and the noncustodial parent is determined by a jury, the court shall charge the provisions of this Code section applicable to the determination of gross income. The jury shall be required to return a special interrogatory determining gross income. The court shall determine adjusted income, health insurance costs, and work related child care costs. Based upon the jury's verdict as to gross income, the court shall determine the presumptive amount of child support in accordance with the provisions of this Code section. The court shall inform the jury of the presumptive amount of child support and the identity of the custodial and noncustodial parents. In the final instructions to the jury, the court shall charge the provisions of this Code section applicable to the determination of deviations and the jury shall be required to return a special interrogatory as to deviations and the final award of child support. The court shall include its findings and the jury's verdict on the child support worksheet in accordance with this Code section and Code Section 19-5-12.
   6. Nothing contained within this Code section shall prevent the parties from entering into an enforceable agreement contrary to the presumptive amount of child support which may be made the order of the court pursuant to review by the court of the adequacy of the child support amounts negotiated by the parties, including the provision for medical expenses and health insurance; provided, however, that if the agreement negotiated by the parties does not comply with the provisions contained in this Code section and does not contain findings of fact as required to support a deviation, the court shall reject such agreement.
   7. In any case filed pursuant to Chapter 11 of this title, relating to the "Child Support Recovery Act," the "Uniform Reciprocal Enforcement of Support Act," or the "Uniform Interstate Family Support Act," the court shall make all determinations of fact, including gross income and deviations, and a jury shall not hear any issue related to such cases.
4. Nature of guidelines; court's discretion. In the event of a hearing or trial on the issue of child support, the guidelines enumerated in this Code section are intended by the General Assembly to be guidelines only and any court so applying such guidelines shall not abrogate its responsibility in making the final determination of child support based on the evidence presented to it at the time of the hearing or trial. A court's final determination of child support shall take into account the obligor's earnings, income, and other evidence of the obligor's ability to pay. The court or the jury shall also consider the basic subsistence needs of the parents and the child for whom support is to be provided.
5. Duration of child support responsibility. The duty to provide support for a minor child shall continue until the child reaches the age of majority, dies, marries, or becomes emancipated, whichever first occurs; provided, however, that, in any temporary, final, or modified order for child support with respect to any proceeding for divorce, separate maintenance, legitimacy, or paternity entered on or after July 1, 1992, the court, in the exercise of sound discretion, may direct either or both parents to provide financial assistance to a child who has not previously married or become emancipated, who is enrolled in and attending a secondary school, and who has attained the age of majority before completing his or her secondary school education, provided that such financial assistance shall not be required after a child attains 20 years of age. The provisions for child support provided in this subsection may be enforced by either parent, by any nonparent custodian, by a guardian appointed to receive child support for the child for whose benefit the child support is ordered, or by the child for whose benefit the child support is ordered.
6. Gross income.
   1. Inclusion to gross income.
      1. Attributable income. Gross income of each parent shall be determined in the process of setting the presumptive amount of child support and shall include all income from any source, before deductions for taxes and other deductions such as preexisting orders for child support and credits for other qualified children, whether earned or unearned, and includes, but is not limited to, the following:
         1. Salaries;
         2. Commissions, fees, and tips;
         3. Income from self-employment;
         4. Bonuses;
         5. Overtime payments;
         6. Severance pay;
         7. Recurring income from pensions or retirement plans, including, but not limited to, United States Department of Veterans Affairs, Railroad Retirement Board, Keoghs, and individual retirement accounts;
         8. Interest income;
         9. Dividend income;
         10. Trust income;
         11. Income from annuities;
         12. Capital gains;
         13. Disability or retirement benefits that are received from the Social Security Administration pursuant to Title II of the federal Social Security Act;
         14. Disability benefits that are received pursuant to the federal Veterans' Benefits Act of 2010, 38 U.S.C. Section 101, et seq.;
         15. Workers' compensation benefits, whether temporary or permanent;
         16. Unemployment insurance benefits;
         17. Judgments recovered for personal injuries and awards from other civil actions;
         18. Gifts that consist of cash or other liquid instruments, or which can be converted to cash;
         19. Prizes;
         20. Lottery winnings;
         21. Alimony or maintenance received from persons other than parties to the proceeding before the court;
         22. Assets which are used for the support of the family; and
         23. Other income.
      2. Self-employment income. Income from self-employment includes income from, but not limited to, business operations, work as an independent contractor or consultant, sales of goods or services, and rental properties, less ordinary and reasonable expenses necessary to produce such income.Income from self-employment, rent, royalties, proprietorship of a business, or joint ownership of a partnership, limited liability company, or closely held corporation is defined as gross receipts minus ordinary and reasonable expenses required for self-employment or business operations.Ordinary and reasonable expenses of self-employment or business operations necessary to produce income do not include:
         1. Excessive promotional, travel, vehicle, or personal living expenses, depreciation on equipment, or costs of operation of home offices; or
         2. Amounts allowable by the Internal Revenue Service for the accelerated component of depreciation expenses, investment tax credits, or any other business expenses determined by the court or the jury to be inappropriate for determining gross income.

         In general, income and expenses from self-employment or operation of a business should be carefully reviewed by the court or the jury to determine an appropriate level of gross income available to the parent to satisfy a child support obligation. Generally, this amount will differ from a determination of business income for tax purposes.

      3. Fringe benefits. Fringe benefits for inclusion as income or "in kind" remuneration received by a parent in the course of employment, or operation of a trade or business, shall be counted as income if the benefits significantly reduce personal living expenses. Such fringe benefits might include, but are not limited to, use of a company car, housing, or room and board. Fringe benefits shall not include employee benefits that are typically added to the salary, wage, or other compensation that a parent may receive as a standard added benefit, including, but not limited to, employer paid portions of health insurance premiums or employer contributions to a retirement or pension plan.
      4. Variable income. Variable income such as commissions, bonuses, overtime pay, military bonuses, and dividends shall be averaged by the court or the jury over a reasonable period of time consistent with the circumstances of the case and added to a parent's fixed salary or wages to determine gross income.When income is received on an irregular, nonrecurring, or one-time basis, the court or the jury may, but is not required to, average or prorate the income over a reasonable specified period of time or require theparent to pay as a one-time support amount a percentage of his or her nonrecurring income, taking into consideration the percentage of recurring income of that parent.
      5. Military compensation and allowances. Income for a parent who is an active duty member of the regular or reserve component of the United States armed forces, the United States Coast Guard, the merchant marine of the United States, the commissioned corps of the Public Health Service or the National Oceanic and Atmospheric Administration, the National Guard, or the Air National Guard shall include:
         1. Base pay;
         2. Drill pay;
         3. Basic allowance for subsistence, whether paid directly to the parent or received in-kind; and
         4. Basic allowance for housing, whether paid directly to the parent or received in-kind, determined at the parent's pay grade at the without dependent rate, but shall include only so much of the allowance that is not attributable to area variable housing costs.

         Except as determined by the court or the jury, special pay or incentive pay, allowances for clothing or family separation, and reimbursed expenses related to the parent's assignment to a high cost of living location shall not be considered income for the purpose of determining gross income.

   2. Exclusions from gross income. Excluded from gross income are the following:
      1. Child support payments received by either parent for the benefit of a child of another relationship;
      2. Benefits received from means-tested public assistance programs such as, but not limited to:
         1. PeachCare for Kids Program, Temporary Assistance for Needy Families Program, or similar programs in other states or territories under Title IV-A of the federal Social Security Act;
         2. Food stamps or the value of food assistance provided by way of electronic benefits transfer procedures by the Department of Human Services;
         3. Supplemental security income received under Title XVI of the federal Social Security Act;
         4. Benefits received under Section 402(d) of the federal Social Security Act for disabled adult children of deceased disabled workers; and
         5. Low-income heating and energy assistance program payments;
      3. Foster care payments paid by the Department of Human Services or a licensed child-placing agency for providing foster care to a foster child in the custody of the Department of Human Services;
      4. A nonparent custodian's gross income; and
      5. Benefits received under Title IV-B or IV-E of the federal Social Security Act and state funding associated therewith for adoption assistance.
   3. Social Security benefits.
      1. Benefits received under Title II of the federal Social Security Act by a child on the obligor's account shall be counted as child support payments and shall be applied against the final child support amount to be paid by the obligor for the child.
      2. After calculating the obligor's monthly gross income, including the countable social security benefits as specified in division (1)(A)(xiii) of this subsection, and after calculating the amount of child support, if the presumptive amount of child support, as increased or decreased by deviations, is greater than the social security benefits paid on behalf of the child on the obligor's account, the obligor shall be required to pay the amount exceeding the social security benefit as part of the final order in the case.
      3. After calculating the obligor's monthly gross income, including the countable social security benefits as specified in division (1)(A)(xiii) of this subsection, and after calculating the amount of child support, if the presumptive amount of child support, as increased or decreased by deviations, is equal to or less than the social security benefits paid to the nonparent custodian or custodial parent on behalf of the child on the obligor's account, the child support responsibility of that parent shall have been met and no further child support shall be paid.
      4. Any benefit amounts under Title II of the federal Social Security Act as determined by the Social Security Administration sent to the nonparent custodian or custodial parent by the Social Security Administration for the child's benefit which are greater than the final child support amount shall be retained by the nonparent custodian or custodial parent for the child's benefit and shall not be used as a reason for decreasing the final child support amount or reducing arrearages.
   4. Reliable evidence of income.
      1. Imputed income. When establishing the amount of child support, if a parent fails to produce reliable evidence of income, such as tax returns for prior years, check stubs, or other information for determining current ability to pay child support or ability to pay child support in prior years, and the court or the jury has no other reliable evidence of the parent's income or income potential, gross income for the current year may be imputed. When imputing income, the court or the jury shall take into account the specific circumstances of the parent to the extent known, including such factors as the parent's assets, residence, employment and earnings history, job skills, educational attainment, literacy, age, health, criminal record and other employment barriers, and record of seeking work, as well as the local job market, the availability of employers willing to hire the parent, prevailing earnings level in the local community, and other relevant background factors in the case. If a parent is incarcerated, the court or the jury shall not assume an ability for earning capacity based upon pre-incarceration wages or other employment related income, but income may be imputed based upon the actual income and assets available to such incarcerated parent.
      2. Modification. When cases with established orders are reviewed for modification and a parent fails to produce reliable evidence of income, such as tax returns for prior years, check stubs, or other information for determining current ability to pay child support or ability to pay child support in prior years, and the court or the jury has no other reliable evidence of such parent's income or income potential, the court or the jury may impute income as set forth in subparagraph (A) of this paragraph, or may increase the child support of the parent failing or refusing to produce evidence of income by an increment of at least 10 percent per year of such parent's gross income for each year since the final order was entered or last modified and shall calculate the basic child support obligation using the increased amount as such parent's gross income.
      3. Rehearing. If income is imputed pursuant to subparagraph (A) of this paragraph, the party believing the income of the other party is higher than the amount imputed may provide within 90 days, upon motion to the court, evidence necessary to determine the appropriate amount of child support based upon reliable evidence. A hearing shall be scheduled after the motion is filed. The court may increase, decrease, or leave unchanged the amount of current child support from the date of filing of either parent's initial filing or motion for reconsideration. While the motion for reconsideration is pending, the obligor shall be responsible for the amount of child support originally ordered. Arrearages entered in the original child support order based upon imputed income shall not be forgiven. When there is reliable evidence to support a motion for reconsideration of the amount of income imputed, the party seeking reconsideration shall not be required to prove the existence of grounds for modification of an order pursuant to subsection (k) of this Code section.
      4. Willful or voluntary unemployment or underemployment. In determining whether a parent is willfully or voluntarily unemployed or underemployed, the court or the jury shall ascertain the reasons for the parent's occupational choices and assess the reasonableness of these choices in light of the parent's responsibility to support his or her child and whether such choices benefit the child. A determination of willful or voluntary unemployment or underemployment shall not be limited to occupational choices motivated only by an intent to avoid or reduce the payment of child support but can be based on any intentional choice or act that affects a parent's income. A determination of willful or voluntary unemployment or underemployment shall not be made when an individual's incarceration prevents employment. In determining willful or voluntary unemployment or underemployment, the court or the jury may examine whether there is a substantial likelihood that the parent could, with reasonable effort, apply his or her education, skills, or training to produce income. Specific factors for the court or the jury to consider when determining willful or voluntary unemployment or underemployment include, but are not limited to:
         1. The parent's past and present employment;
         2. The parent's education and training;
         3. Whether unemployment or underemployment for the purpose of pursuing additional training or education is reasonable in light of the parent's responsibility to support his or her child and, to this end, whether the training or education may ultimately benefit the child in the case immediately under consideration by increasing the parent's level of support for that child in the future;
         4. A parent's ownership of valuable assets and resources, such as an expensive home or automobile, that appear inappropriate or unreasonable for the income claimed by the parent;
         5. The parent's own health and ability to work outside the home; and
         6. The parent's role as caretaker of a child of that parent, a disabled or seriously ill child of that parent, or a disabled or seriously ill adult child of that parent, or any other disabled or seriously ill relative for whom that parent has assumed the role of caretaker, which eliminates or substantially reduces the parent's ability to work outside the home, and the need of that parent to continue in the role of caretaker in the future. When considering the income potential of a parent whose work experience is limited due to the caretaker role of that parent, the court or the jury shall consider the following factors:
      5. Whether the parent acted in the role of full-time caretaker immediately prior to separation by the married parties or prior to the divorce or annulment of the marriage or dissolution of another relationship in which the parent was a full-time caretaker;
      6. The length of time the parent staying at home has remained out of the work force for this purpose;
      7. The parent's education, training, and ability to work; and
      8. Whether the parent is caring for a child who is four years of age or younger. If the court or the jury determines that a parent is willfully or voluntarily unemployed or underemployed, child support shall be calculated based on a determination of earning capacity, as evidenced by educational level or previous work experience. In the absence of any other reliable evidence, income may be imputed to the parent as provided for in subparagraph (f)(4)(A) of this Code section.

         A determination of willful and voluntary unemployment or underemployment shall not be made when an individual is activated from the National Guard or other armed forces unit or enlists or is drafted for full-time service in the armed forces of the United States.

   5. Adjustments to gross income.
      1. Self-employment. One-half of the self-employment and Medicare taxes shall be calculated as follows:
         1. Six and two-tenths percent of self-employment income up to the maximum amount to which federal old age, survivors, and disability insurance (OASDI) applies; plus
         2. One and forty-five one-hundredths of a percent of self-employment income for Medicare

         and this amount shall be deducted from a self-employed parent's monthly gross income.

      2. Preexisting orders. An adjustment to the parent's monthly gross income shall be made on the Child Support Schedule B - Adjusted Income for current preexisting orders for a period of not less than 12 months immediately prior to the date of the hearing or such period that an order has been in effect if less than 12 months prior to the date of the hearing before the court to set, modify, or enforce child support.
         1. In calculating the adjustment for preexisting orders, the court shall include only those preexisting orders meeting the criteria set forth in subparagraph (a)(18)(B) of this Code section;
         2. The priority for preexisting orders shall be determined by the date and time of filing with the clerk of court of the initial order in each case. Subsequent modifications of the initial support order shall not affect the priority position established by the date and time of the initial order. In any modification proceeding, the court rendering the decision shall make a specific finding of the date, and time if known, of the initial order of the case;
         3. Adjustments shall be allowed for current preexisting support only to the extent that the payments are actually being paid as evidenced by documentation including, but not limited to, payment history from a court clerk, the child support services' computer data base, the child support payment history, or canceled checks or other written proof of payments paid directly to the other parent. The maximum credit allowed for a preexisting order is an average of the amount of current support actually paid under the preexisting order over the past 12 months prior to the hearing date;
         4. All preexisting orders shall be entered on the Child Support Schedule B - Adjusted Income for the purpose of calculating the total amount of the credit to be included on the child support worksheet; and
         5. Payments being made by a parent on any arrearages shall not be considered payments on preexisting orders or subsequent orders and shall not be used as a basis for reducing gross income.
      3. Theoretical child support orders. In addition to the adjustments to monthly gross income for self-employment taxes provided in subparagraph (A) of this paragraph and for preexisting orders provided in subparagraph (B) of this paragraph, credits for either parent's other qualified child living in the parent's home for whom the parent owes a legal duty of support may be considered by the court for the purpose of reducing the parent's gross income. To consider a parent's other qualified children for determining the theoretical child support order, a parent shall present documentary evidence of the parent-child relationship to the court. Adjustments to income pursuant to this subparagraph may be considered in such circumstances in which the failure to consider a qualified child would cause substantial hardship to the parent; provided, however, that such consideration of an adjustment shall be based upon the best interest of the child for whom child support is being awarded. If the court, in its discretion, decides to apply the qualified child adjustment, the basic child support obligation of the parent for the number of other qualified children living with such parent shall be determined based upon that parent's monthly gross income. Except for self-employment taxes paid, no other amounts shall be subtracted from the parent's monthly gross income when calculating a theoretical child support order under this subparagraph. The basic child support obligation for such parent shall be multiplied by 75 percent and the resulting amount shall be subtracted from such parent's monthly gross income and entered on the Child Support Schedule B - Adjusted Income.
      4. Multiple family situations. In multiple family situations, the priority of adjustments to a parent's monthly gross income shall be calculated in the following order:
         1. Preexisting orders according to the date and time of the initial order as set forth in subparagraph (B) of this paragraph; and
         2. Application of any credit for a parent's other qualified children using the procedure set forth in subparagraph (C) of this paragraph.
7. Parenting time deviation. The court or the jury may deviate from the presumptive amount of child support as set forth in subparagraph (i)(2)(K) of this Code section.
8. Adjusted support obligation. The child support obligation table does not include the cost of the parent's work related child care costs, health insurance premiums, or uninsured health care expenses. The additional expenses for the child's health insurance premiums and work related child care costs shall be included in the calculations to determine child support. A nonparent custodian's expenses for work related child care costs and health insurance premiums shall be taken into account when establishing a final order.
   1. Work related child care costs.
      1. Work related child care costs necessary for the parent's employment, education, or vocational training that are determined by the court to be appropriate, and that are appropriate to the parents' financial abilities and to the lifestyle of the child if the parents and child were living together, shall be averaged for a monthly amount and entered on the child support worksheet in the column of the parent initially paying the expense. Work related child care costs of a nonparent custodian shall be considered when determining the amount of this expense.
      2. If a child care subsidy is being provided pursuant to a means-tested public assistance program, only the amount of the child care expense actually paid by either parent or a nonparent custodian shall be included in the calculation.
      3. If either parent is the provider of child care services to the child for whom support is being determined, the value of those services shall not be an adjustment to the basic child support obligation when calculating the support award.
      4. If child care is provided without charge to the parent, the value of these services shall not be an adjustment to the basic child support obligation. If child care is or will be provided by a person who is paid for his or her services, proof of actual cost or payment shall be shown to the court before the court includes such payment in its consideration.
      5. The amount of work related child care costs shall be determined and added as an adjustment to the basic child support obligation as "additional expenses" whether paid directly by the parent or through a payroll deduction.
      6. 1. The total amount of work related child care costs shall be divided between the parents pro rata to determine the presumptive amount of child support and shall be included in the worksheet and the final order.
         2. In situations in which work related child care costs may be variable, the court or the jury may, in its discretion, remove work related child care costs from the calculation of support, and divide the work related child care costs pro rata, to be paid within a time specified in the final order. If a parent or nonparent custodian fails to comply with the final order:
      7. The other parent or nonparent custodian may enforce payment of the work related child care costs by any means permitted by law; or
      8. Child support services shall pursue enforcement when such unpaid costs have been reduced to a judgment in a sum certain.
   2. Cost of health insurance premiums.
      1. 1. The amount that is, or will be, paid by a parent for health insurance for the child for whom support is being determined shall be an adjustment to the basic child support obligation and prorated between the parents based upon their respective incomes. Payments made by a parent's employer for health insurance and not deducted from the parent's wages shall not be included. When a child for whom support is being determined is covered by a family policy, only the health insurance premium actually attributable to that child shall be added.
         2. The amount of the cost for the child's health insurance premium shall be determined and added as an adjustment to the basic child support obligation as "additional expenses" whether paid directly by the parent or through a payroll deduction.
         3. The total amount of the cost for the child's health insurance premium shall be divided between the parents pro rata to determine the total presumptive amount of child support and shall be included in the Child Support Schedule D - Additional Expenses and written order of the court together with the amount of the basic child support obligation.
      2. 1. If either parent has health insurance reasonably available at reasonable cost that provides for the health care needs of the child, then an amount to cover the cost of the premium shall be added as an adjustment to the basic child support obligation. A health insurance premium paid by a nonparent custodian shall be included when determining the amount of health insurance expense. In determining the amount to be added to the order for the health insurance cost, only the amount of the health insurance cost attributable to the child who is the subject of the order shall be included.
         2. If coverage is applicable to other persons and the amount of the health insurance premium attributable to the child who is the subject of the current action for support is not verifiable, the total cost to the parent paying the premium shall be prorated by the number of persons covered so that only the cost attributable to the child who is the subject of the order under consideration is included. The amount of health insurance premium shall be determined by dividing the total amount of the insurance premium by the number of persons covered by the insurance policy and multiplying the resulting amount by the number of children covered by the insurance policy. The monthly cost of health insurance premium shall be entered on the Child Support Schedule D - Additional Expenses in the column of the parent paying the premium.
         3. Eligibility for or enrollment of the child in Medicaid, the PeachCare for Kids Program, or other public health care program shall satisfy the requirement that the final order provide for the child's health care needs. Health coverage through Medicaid, the PeachCare for Kids Program, or other public health care program shall not prevent a court from also ordering either or both parents to obtain other health insurance for the child.
   3. Uninsured health care expenses.
      1. The child's uninsured health care expenses shall be the financial responsibility of both parents. The final order shall include provisions for payment of uninsured health care expenses; provided, however, that uninsured health care expenses shall not be used for the purpose of calculating the amount of child support. The parents shall divide uninsured health care expenses pro rata, unless otherwise specifically ordered by the court.
      2. If a parent fails to pay his or her pro rata share of the child's uninsured health care expenses, as specified in the final order, within a reasonable time after receipt of evidence documenting the uninsured portion of the expense:
9. The other parent or the nonparent custodian may enforce payment of the expense by any means permitted by law; or
   1. General principles.
      1. The amount of child support established by this Code section and the presumptive amount of child support are rebuttable and the court or the jury may deviate from the presumptive amount of child support in compliance with this subsection. In deviating from the presumptive amount of child support, consideration shall be given to the best interest of the child for whom support under this Code section is being determined. A nonparent custodian's expenses may be the basis for a deviation as well as a noncustodial parent's ability or inability to pay the presumptive amount of child support.
      2. When ordering a deviation from the presumptive amount of child support, the court or the jury shall consider all available income of the parents and shall make written findings or special interrogatory findings that an amount of child support other than the amount calculated is reasonably necessary to provide for the needs of the child for whom child support is being determined and the order or special interrogatory shall state:
         1. The reasons for the deviation from the presumptive amount of child support;
         2. The amount of child support that would have been required under this Code section if the presumptive amount of child support had not been rebutted; and
         3. How, in its determination:
      3. Application of the presumptive amount of child support would be unjust or inappropriate; and
      4. The best interest of the child for whom support is being determined will be served by deviation from the presumptive amount of child support.
      5. No deviation in the presumptive amount of child support shall be made which seriously impairs the ability of the custodial parent to maintain minimally adequate housing, food, and clothing for the child being supported by the order and to provide other basic necessities, as determined by the court or the jury.
      6. If the circumstances which supported the deviation cease to exist, the final order may be modified as set forth in subsection (k) of this Code section to eliminate the deviation.
   2. Specific deviations.
      1. High income. For purposes of this subparagraph, parents are considered to be high-income parents if their combined adjusted income exceeds $30,000.00 per month.For high-income parents, the court shall set the basic child support obligation at the highest amount allowed by the child support obligation table but the court or the jury may consider upward deviation to attain an appropriate award of child support for high-income parents which is consistent with the best interest of the child.
      2. Low income.
         1. If the noncustodial parent can provide evidence sufficient to demonstrate no earning capacity or that his or her pro rata share of the presumptive amount of child support would create an extreme economic hardship for such parent, the court or the jury may consider a low-income deviation.
         2. A noncustodial parent whose sole source of income is supplemental security income received under Title XVI of the federal Social Security Act shall be considered to have no earning capacity.
         3. The court or the jury shall examine all attributable and excluded sources of income, assets, and benefits available to the noncustodial parent and may consider the noncustodial parent's basic subsistence needs and all of his or her reasonable expenses, ensuring that such expenses are actually paid by the noncustodial parent and are clearly justified expenses.
         4. In considering a request for a low-income deviation, the court or the jury shall then weigh the income and all attributable and excluded sources of income, assets, and benefits and all reasonable expenses of each parent, the relative hardship that a reduction in the amount of child support paid to the custodial parent would have on the custodial parent's household, the needs of each parent, the needs of the child for whom child support is being determined, and the ability of the noncustodial parent to pay child support.
         5. Following a review of the noncustodial parent's gross income and expenses, and taking into account each parent's basic child support obligation adjusted by health insurance and work related child care costs and the relative hardships on the parents and the child, the court or the jury, upon request by either party or upon the court's initiative, may consider a downward deviation to attain an appropriate award of child support which is consistent with the best interest of the child.
         6. For the purpose of calculating a low-income deviation, the noncustodial parent's minimum child support for one child shall be not less than $100.00 per month, and such amount shall be increased by at least $50.00 for each additional child for the same case for which child support is being ordered.
         7. A low-income deviation granted pursuant to this subparagraph shall apply only to the current child support amount and shall not prohibit an additional amount being ordered to reduce a noncustodial parent's arrears.
         8. If a low-income deviation is granted pursuant to this subparagraph, such deviation shall not prohibit the court or the jury from granting an increase or decrease to the presumptive amount of child support by the use of any other specific or nonspecific deviation.
      3. Other health related insurance. If the court or the jury finds that either parent has vision or dental insurance available at a reasonable cost for the child, the court or the jury may deviate from the presumptive amount of child support for the cost of such insurance.
      4. Life insurance. In accordance with Code Section 19-6-34, if the court or the jury finds that either parent has purchased life insurance on the life of either parent or the lives of both parents for the benefit of the child, the court may deviate from the presumptive amount of child support for the cost of such insurance by either adding or subtracting the amount of the premium.
      5. Child and dependent care tax credit. If the court or the jury finds that one of the parents is entitled to the Child and Dependent Care Tax Credit, the court or the jury may deviate from the presumptive amount of child support in consideration of such credit.
      6. Travel expenses. If court ordered visitation related travel expenses are substantial due to the distance between the parents, the court may order the allocation of such costs or the jury may, by a finding in its special interrogatory, allocate such costs by deviation from the presumptive amount of child support, taking into consideration the circumstances of the respective parents as well as which parent moved and the reason for such move.
      7. Alimony. Actual payments of alimony shall not be considered as a deduction from gross income but may be considered as a deviation from the presumptive amount of child support. If the court or the jury considers the actual payment of alimony, the court shall make a written finding of such consideration or the jury, in its special interrogatory, shall make a written finding of such consideration as a basis for deviation from the presumptive amount of child support.
      8. Mortgage. If the noncustodial parent is providing shelter, such as paying the mortgage of the home, or has provided a home at no cost to the custodial parent in which the child resides, the court or the jury may allocate such costs or an amount equivalent to such costs by deviation from the presumptive amount of child support, taking into consideration the circumstances of the respective parents and the best interest of the child.
      9. Permanency plan or foster care plan. In cases when the child is in the legal custody of the Department of Human Services, the child protection or foster care agency of another state or territory, or any other child-caring entity, public or private, the court or the jury may consider a deviation from the presumptive amount of child support if the deviation will assist in accomplishing a permanency plan or foster care plan for the child that has a goal of returning the child to the parent or parents and the parent's need to establish an adequate household or to otherwise adequately prepare herself or himself for the return of the child clearly justifies a deviation for this purpose.
      10. Extraordinary expenses. The child support obligation table includes average child-rearing expenditures for families given the parents' combined adjusted income and number of children. Extraordinary expenses are in excess of average amounts estimated in the child support obligation table and are highly variable among families. Extraordinary expenses shall be considered on a case-by-case basis in the calculation of support and may form the basis for deviation from the presumptive amount of child support so that the actual amount of such expense is considered in the final order for only those families actually incurring the expense. Extraordinary expenses shall be prorated between the parents by assigning or deducting credit for actual payments for extraordinary expenses.
          1. Extraordinary educational expenses. Extraordinary educational expenses may be a basis for deviation from the presumptive amount of child support. Extraordinary educational expenses include, but are not limited to, tuition, room and board, lab fees, books, fees, and other reasonable and necessary expenses associated with special needs education or private elementary and secondary schooling that are appropriate to the parent's financial abilities and to the lifestyle of the child if the parents and the child were living together.
      11. In determining the amount of deviation for extraordinary educational expenses, scholarships, grants, stipends, and other cost-reducing programs received by or on behalf of the child shall be considered; and
      12. If a deviation is allowed for extraordinary educational expenses, a monthly average of the extraordinary educational expenses shall be based on evidence of prior or anticipated expenses and entered on the Child Support Schedule E - Deviations.
          1. Special expenses incurred for child-rearing. Special expenses incurred for child-rearing, including, but not limited to, quantifiable expense variations related to the food, clothing, and hygiene costs of children at different age levels, may be a basis for a deviation from the presumptive amount of child support. Such expenses include, but are not limited to, summer camp; music or art lessons; travel; school sponsored extracurricular activities, such as band, clubs, and athletics; and other activities intended to enhance the athletic, social, or cultural development of a child but not otherwise required to be used in calculating the presumptive amount of child support as are health insurance premiums and work related child care costs. A portion of the basic child support obligation is intended to cover average amounts of special expenses incurred in the rearing of a child. In order to determine if a deviation for special expenses is warranted, the court or the jury shall consider the full amount of the special expenses as described in this division; and when such special expenses exceed 7 percent of the basic child support obligation, then the additional amount of special expenses shall be considered as a deviation to cover the full amount of the special expenses.
          2. Extraordinary medical expenses. In instances of extreme economic hardship involving extraordinary medical expenses not covered by insurance, the court or the jury may consider a deviation from the presumptive amount of child support for extraordinary medical expenses. Such expenses may include, but are not limited to, extraordinary medical expenses of the child or a parent of the child; provided, however, that any such deviation:
      13. Shall not act to leave a child unsupported; and
      14. May be ordered for a specific period of time measured in months.

          When extraordinary medical expenses are claimed, the court or the jury shall consider the resources available for meeting such needs, including sources available from agencies and other adults.

      15. Parenting time.
          1. The child support obligation table is based upon expenditures for a child in intact households. The court may order or the jury may find by special interrogatory a deviation from the presumptive amount of child support when special circumstances make the presumptive amount of child support excessive or inadequate due to extended parenting time as set forth in the order of visitation, the child residing with both parents equally, or visitation rights not being utilized.
          2. If the court or the jury determines that a parenting time deviation is applicable, then such deviation shall be included with all other deviations.
          3. In accordance with subsection (d) of Code Section 19-11-8, if any action or claim for parenting time or a parenting time deviation is brought under this subparagraph, it shall be an action or claim solely between the custodial parent and the noncustodial parent, and not any third parties, including child support services.
   3. Nonspecific deviations. Deviations from the presumptive amount of child support may be appropriate for reasons in addition to those established under this subsection when the court or the jury finds it is in the best interest of the child.
10. Involuntary loss of income.
    1. In the event a parent suffers an involuntary termination of employment, has an extended involuntary loss of average weekly hours, is involved in an organized strike, incurs a loss of health, becomes incarcerated, or similar involuntary adversity resulting in a loss of income of 25 percent or more, then the portion of child support attributable to lost income shall not accrue from the date of the service of the petition for modification, provided that service is made on the other parent. It shall not be considered an involuntary termination of employment if the parent has left the employer without good cause in connection with the parent's most recent work.
    2. In the event a modification action is filed pursuant to this subsection, the court shall make every effort to expedite hearing such action.
    3. The court may, at its discretion, phase in the new child support award over a period of up to one year with the phasing in being largely evenly distributed with at least an initial immediate adjustment of not less than 25 percent of the difference and at least one intermediate adjustment prior to the final adjustment at the end of the phase-in period.
11. Modification.
    1. Except as provided in paragraph (2) of this subsection, a parent shall not have the right to petition for modification of the child support award regardless of the length of time since the establishment of the child support award unless there is a substantial change in either parent's income and financial status or the needs of the child.
    2. No petition to modify child support may be filed by either parent within a period of two years from the date of the final order on a previous petition to modify by the same parent except when:
       1. A noncustodial parent has failed to exercise the court ordered visitation;
       2. A noncustodial parent has exercised a greater amount of visitation than was provided in the court order; or
       3. The motion to modify is based upon an involuntary loss of income as set forth in subsection (j) of this Code section.
    3. 1. If there is a difference of at least 15 percent but less than 30 percent between a new award and a Georgia child support order entered prior to January 1, 2007, the court may, at its discretion, phase in the new child support award over a period of up to one year with the phasing in being largely evenly distributed with at least an initial immediate adjustment of not less than 25 percent of the difference and at least one intermediate adjustment prior to the final adjustment at the end of the phase-in period.
       2. If there is a difference of 30 percent or more between a new award and a Georgia child support order entered prior to January 1, 2007, the court may, at its discretion, phase in the new child support award over a period of up to two years with the phasing in being largely evenly distributed with at least an initial immediate adjustment of not less than 25 percent of the difference and at least one intermediate adjustment prior to the final adjustment at the end of the phase-in period.
       3. All child support service's case reviews and modifications shall proceed and be governed by Code Section 19-11-12. Subsequent changes to the child support obligation table shall be a reason to request a review for modification from child support services to the extent that such changes are consistent with the requirements of Code Section 19-11-12.
    4. A petition for modification shall be filed under the same rules of procedure applicable to divorce proceedings. The court may allow, upon motion, the temporary modification of a child support order pending the final trial on the petition. An order granting temporary modification shall be subject to revision by the court at any time before the final trial. A jury may be demanded on a petition for modification but the jury shall only be responsible for determining a parent's gross income and any deviations. In the hearing upon a petition for modification, testimony may be given and evidence introduced relative to the change of circumstances, income and financial status of either parent, or in the needs of the child. After hearing both parties and the evidence, the court may modify and revise the previous judgment, in accordance with the changed circumstances, income and financial status of either parent, or in the needs of the child, if such change or changes are satisfactorily proven so as to warrant the modification and revision and such modification and revisions are in the child's best interest. The court shall enter a written order specifying the basis for the modification, if any, and shall include all of the information set forth in paragraph (2) of subsection (c) of this Code section.
    5. In proceedings for the modification of a child support award pursuant to the provisions of this Code section, the court may award attorney's fees, costs, and expenses of litigation to the prevailing party as the interests of justice may require. When a custodial parent prevails in an upward modification of child support based upon the noncustodial parent's failure to be available and willing to exercise court ordered visitation, reasonable and necessary attorney's fees and expenses of litigation shall be awarded to the custodial parent.
12. Split parenting. In cases of split parenting, a worksheet shall be prepared separately by each custodial parent for each child for whom such parent is the custodial parent, and that worksheet shall be filed with the clerk of court. For each split parenting custodial situation, the court shall determine:
    1. Which parent is the obligor;
    2. The presumptive amount of child support;
    3. The actual award of child support, if different from the presumptive amount of child support;
    4. How and when the sum certain amount of child support owed shall be paid; and
    5. Any other child support responsibilities for each parent.
13. Worksheets.
    1. Schedules and worksheets shall be prepared by the parties for purposes of calculating the amount of child support. In child support services cases in which neither parent prepared a worksheet, the court may rely on the worksheet prepared by child support services as a basis for its order. Information from the schedules shall be entered on the child support worksheet. The child support worksheets and any schedule that was prepared for the purpose of calculating the amount of child support shall be attached to the final court order or judgment; provided, however, that any order entered pursuant to Code Section 19-13-4 shall not be required to have such worksheets and schedules attached thereto.
    2. The child support worksheet and schedules shall be promulgated by the Georgia Child Support Commission.
14. Child support obligation table. The child support obligation table shall be proposed by the Georgia Child Support Commission and shall be as codified in subsection (o) of this Code section.
15. Georgia Schedule of Basic Child Support Obligations.

(a.1) (1)As used in this chapter, the term "child" means child or children, including any unborn child with a detectable human heartbeat as such terms are defined in Code Section 1-2-1.

Notwithstanding any provision of this Code section to the contrary, the maximum amount of support which the court may impose on the father of an unborn child under this Code section shall be the amount of direct medical and pregnancy related expenses of the mother of the unborn child.After birth, the provisions of this Code section shall apply in full.

Child support services shall pursue enforcement of payment of such unpaid expenses only if the unpaid expenses have been reduced to a judgment in a sum certain amount.

Grounds for deviation.

Georgia Schedule of Basic Child Support Obligations Combined One Two Three Four Five Six Adjusted Child Children Children Children Children Children Income $ 800.00 $ 197.00 $ 283.00 $ 330.00 $ 367.00 $ 404.00 $ 440.00 850.00 208.00 298.00 347.00 387.00 425.00 463.00 900.00 218.00 313.00 364.00 406.00 447.00 486.00 950.00 229.00 328.00 381.00 425.00 468.00 509.00 1,000.00 239.00 343.00 398.00 444.00 489.00 532.00 1,050.00 250.00 357.00 415.00 463.00 510.00 554.00 1,100.00 260.00 372.00 432.00 482.00 530.00 577.00 1,150.00 270.00 387.00 449.00 501.00 551.00 600.00 1,200.00 280.00 401.00 466.00 520.00 572.00 622.00 1,250.00 291.00 416.00 483.00 539.00 593.00 645.00 1,300.00 301.00 431.00 500.00 558.00 614.00 668.00 1,350.00 311.00 445.00 517.00 577.00 634.00 690.00 1,400.00 321.00 459.00 533.00 594.00 654.00 711.00 1,450.00 331.00 473.00 549.00 612.00 673.00 733.00 1,500.00 340.00 487.00 565.00 630.00 693.00 754.00 1,550.00 350.00 500.00 581.00 647.00 712.00 775.00 1,600.00 360.00 514.00 597.00 665.00 732.00 796.00 1,650.00 369.00 528.00 612.00 683.00 751.00 817.00 1,700.00 379.00 542.00 628.00 701.00 771.00 838.00 1,750.00 389.00 555.00 644.00 718.00 790.00 860.00 1,800.00 398.00 569.00 660.00 736.00 809.00 881.00 1,850.00 408.00 583.00 676.00 754.00 829.00 902.00 1,900.00 418.00 596.00 692.00 771.00 848.00 923.00 1,950.00 427.00 610.00 708.00 789.00 868.00 944.00 2,000.00 437.00 624.00 723.00 807.00 887.00 965.00 2,050.00 446.00 637.00 739.00 824.00 906.00 986.00 2,100.00 455.00 650.00 754.00 840.00 924.00 1,006.00 2,150.00 465.00 663.00 769.00 857.00 943.00 1,026.00 2,200.00 474.00 676.00 783.00 873.00 961.00 1,045.00 2,250.00 483.00 688.00 798.00 890.00 979.00 1,065.00 2,300.00 492.00 701.00 813.00 907.00 997.00 1,085.00 2,350.00 501.00 714.00 828.00 923.00 1,016.00 1,105.00 2,400.00 510.00 727.00 843.00 940.00 1,034.00 1,125.00 2,450.00 519.00 740.00 858.00 956.00 1,052.00 1,145.00 2,500.00 528.00 752.00 873.00 973.00 1,070.00 1,165.00 2,550.00 537.00 765.00 888.00 990.00 1,089.00 1,184.00 2,600.00 547.00 778.00 902.00 1,006.00 1,107.00 1,204.00 2,650.00 556.00 791.00 917.00 1,023.00 1,125.00 1,224.00 2,700.00 565.00 804.00 932.00 1,039.00 1,143.00 1,244.00 2,750.00 574.00 816.00 947.00 1,056.00 1,162.00 1,264.00 2,800.00 583.00 829.00 962.00 1,073.00 1,180.00 1,284.00 2,850.00 592.00 842.00 977.00 1,089.00 1,198.00 1,303.00 2,900.00 601.00 855.00 992.00 1,106.00 1,216.00 1,323.00 2,950.00 611.00 868.00 1,006.00 1,122.00 1,234.00 1,343.00 3,000.00 620.00 881.00 1,021.00 1,139.00 1,253.00 1,363.00 3,050.00 629.00 893.00 1,036.00 1,155.00 1,271.00 1,383.00 3,100.00 638.00 906.00 1,051.00 1,172.00 1,289.00 1,402.00 3,150.00 647.00 919.00 1,066.00 1,188.00 1,307.00 1,422.00 3,200.00 655.00 930.00 1,079.00 1,203.00 1,323.00 1,440.00 3,250.00 663.00 941.00 1,092.00 1,217.00 1,339.00 1,457.00 3,300.00 671.00 952.00 1,104.00 1,231.00 1,355.00 1,474.00 3,350.00 679.00 963.00 1,117.00 1,246.00 1,370.00 1,491.00 3,400.00 687.00 974.00 1,130.00 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2,806.00 3,086.00 3,358.00 14,550.00 1,596.00 2,217.00 2,521.00 2,811.00 3,092.00 3,365.00 14,600.00 1,599.00 2,221.00 2,526.00 2,817.00 3,098.00 3,371.00 14,650.00 1,602.00 2,225.00 2,531.00 2,822.00 3,104.00 3,378.00 14,700.00 1,605.00 2,230.00 2,536.00 2,828.00 3,111.00 3,384.00 14,750.00 1,608.00 2,234.00 2,541.00 2,833.00 3,117.00 3,391.00 14,800.00 1,611.00 2,238.00 2,546.00 2,839.00 3,123.00 3,397.00 14,850.00 1,614.00 2,243.00 2,551.00 2,844.00 3,129.00 3,404.00 14,900.00 1,617.00 2,247.00 2,556.00 2,850.00 3,135.00 3,411.00 14,950.00 1,620.00 2,251.00 2,561.00 2,855.00 3,141.00 3,417.00 15,000.00 1,623.00 2,255.00 2,566.00 2,861.00 3,147.00 3,424.00 15,050.00 1,626.00 2,260.00 2,571.00 2,866.00 3,153.00 3,430.00 15,100.00 1,629.00 2,264.00 2,576.00 2,872.00 3,159.00 3,437.00 15,150.00 1,632.00 2,268.00 2,581.00 2,877.00 3,165.00 3,444.00 15,200.00 1,635.00 2,272.00 2,585.00 2,883.00 3,171.00 3,450.00 15,250.00 1,638.00 2,277.00 2,590.00 2,888.00 3,177.00 3,457.00 15,300.00 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3,274.00 3,562.00 16,100.00 1,690.00 2,349.00 2,674.00 2,982.00 3,280.00 3,569.00 16,150.00 1,692.00 2,353.00 2,678.00 2,986.00 3,285.00 3,574.00 16,200.00 1,695.00 2,356.00 2,682.00 2,990.00 3,289.00 3,579.00 16,250.00 1,698.00 2,360.00 2,686.00 2,994.00 3,294.00 3,584.00 16,300.00 1,700.00 2,363.00 2,689.00 2,999.00 3,299.00 3,589.00 16,350.00 1,703.00 2,367.00 2,693.00 3,003.00 3,303.00 3,594.00 16,400.00 1,706.00 2,370.00 2,697.00 3,007.00 3,308.00 3,599.00 16,450.00 1,708.00 2,374.00 2,701.00 3,011.00 3,313.00 3,604.00 16,500.00 1,711.00 2,377.00 2,705.00 3,016.00 3,317.00 3,609.00 16,550.00 1,714.00 2,381.00 2,708.00 3,020.00 3,322.00 3,614.00 16,600.00 1,716.00 2,384.00 2,712.00 3,024.00 3,327.00 3,619.00 16,650.00 1,719.00 2,388.00 2,716.00 3,028.00 3,331.00 3,624.00 16,700.00 1,722.00 2,391.00 2,720.00 3,033.00 3,336.00 3,630.00 16,750.00 1,724.00 2,395.00 2,724.00 3,037.00 3,341.00 3,635.00 16,800.00 1,727.00 2,398.00 2,728.00 3,041.00 3,345.00 3,640.00 16,850.00 1,730.00 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1,936.00 2,674.00 3,028.00 3,377.00 3,714.00 4,041.00 20,800.00 1,938.00 2,677.00 3,032.00 3,381.00 3,719.00 4,046.00 20,850.00 1,941.00 2,681.00 3,036.00 3,385.00 3,724.00 4,051.00 20,900.00 1,944.00 2,684.00 3,040.00 3,389.00 3,728.00 4,056.00 20,950.00 1,946.00 2,688.00 3,044.00 3,394.00 3,733.00 4,062.00 21,000.00 1,949.00 2,691.00 3,047.00 3,398.00 3,738.00 4,067.00 21,050.00 1,952.00 2,695.00 3,051.00 3,402.00 3,742.00 4,072.00 21,100.00 1,954.00 2,698.00 3,055.00 3,406.00 3,747.00 4,077.00 21,150.00 1,957.00 2,702.00 3,059.00 3,411.00 3,752.00 4,082.00 21,200.00 1,960.00 2,705.00 3,063.00 3,415.00 3,756.00 4,087.00 21,250.00 1,962.00 2,709.00 3,067.00 3,419.00 3,761.00 4,092.00 21,300.00 1,965.00 2,712.00 3,070.00 3,423.00 3,766.00 4,097.00 21,350.00 1,968.00 2,716.00 3,074.00 3,428.00 3,770.00 4,102.00 21,400.00 1,970.00 2,719.00 3,078.00 3,432.00 3,775.00 4,107.00 21,450.00 1,973.00 2,723.00 3,082.00 3,436.00 3,780.00 4,112.00 21,500.00 1,975.00 2,726.00 3,086.00 3,440.00 3,784.00 4,117.00 21,550.00 1,978.00 2,730.00 3,089.00 3,445.00 3,789.00 4,123.00 21,600.00 1,981.00 2,733.00 3,093.00 3,449.00 3,794.00 4,128.00 21,650.00 1,983.00 2,737.00 3,097.00 3,453.00 3,798.00 4,133.00 21,700.00 1,986.00 2,740.00 3,101.00 3,457.00 3,803.00 4,138.00 21,750.00 1,989.00 2,744.00 3,105.00 3,462.00 3,808.00 4,143.00 21,800.00 1,991.00 2,747.00 3,108.00 3,466.00 3,812.00 4,148.00 21,850.00 1,994.00 2,751.00 3,112.00 3,470.00 3,817.00 4,153.00 21,900.00 1,997.00 2,754.00 3,116.00 3,474.00 3,822.00 4,158.00 21,950.00 1,999.00 2,758.00 3,120.00 3,479.00 3,827.00 4,163.00 22,000.00 2,002.00 2,761.00 3,124.00 3,483.00 3,831.00 4,168.00 22,050.00 2,005.00 2,765.00 3,127.00 3,487.00 3,836.00 4,173.00 22,100.00 2,007.00 2,768.00 3,131.00 3,491.00 3,841.00 4,178.00 22,150.00 2,010.00 2,772.00 3,135.00 3,496.00 3,845.00 4,184.00 22,200.00 2,012.00 2,775.00 3,139.00 3,500.00 3,850.00 4,189.00 22,250.00 2,015.00 2,779.00 3,143.00 3,504.00 3,855.00 4,194.00 22,300.00 2,018.00 2,782.00 3,147.00 3,508.00 3,859.00 4,199.00 22,350.00 2,020.00 2,785.00 3,150.00 3,513.00 3,864.00 4,204.00 22,400.00 2,022.00 2,788.00 3,153.00 3,515.00 3,867.00 4,207.00 22,450.00 2,024.00 2,790.00 3,155.00 3,517.00 3,869.00 4,210.00 22,500.00 2,025.00 2,792.00 3,157.00 3,520.00 3,872.00 4,212.00 22,550.00 2,027.00 2,793.00 3,158.00 3,522.00 3,874.00 4,215.00 22,600.00 2,028.00 2,795.00 3,160.00 3,524.00 3,876.00 4,217.00 22,650.00 2,029.00 2,797.00 3,162.00 3,526.00 3,878.00 4,220.00 22,700.00 2,031.00 2,799.00 3,164.00 3,528.00 3,881.00 4,222.00 22,750.00 2,032.00 2,801.00 3,166.00 3,530.00 3,883.00 4,225.00 22,800.00 2,034.00 2,803.00 3,168.00 3,532.00 3,885.00 4,227.00 22,850.00 2,035.00 2,804.00 3,169.00 3,534.00 3,888.00 4,230.00 22,900.00 2,036.00 2,806.00 3,171.00 3,536.00 3,890.00 4,232.00 22,950.00 2,038.00 2,808.00 3,173.00 3,538.00 3,892.00 4,235.00 23,000.00 2,039.00 2,810.00 3,175.00 3,540.00 3,894.00 4,237.00 23,050.00 2,041.00 2,812.00 3,177.00 3,542.00 3,897.00 4,240.00 23,100.00 2,042.00 2,814.00 3,179.00 3,544.00 3,899.00 4,242.00 23,150.00 2,044.00 2,816.00 3,181.00 3,546.00 3,901.00 4,245.00 23,200.00 2,045.00 2,817.00 3,182.00 3,548.00 3,904.00 4,247.00 23,250.00 2,046.00 2,819.00 3,184.00 3,550.00 3,906.00 4,250.00 23,300.00 2,048.00 2,821.00 3,186.00 3,552.00 3,908.00 4,252.00 23,350.00 2,049.00 2,823.00 3,188.00 3,555.00 3,910.00 4,254.00 23,400.00 2,051.00 2,825.00 3,190.00 3,557.00 3,913.00 4,257.00 23,450.00 2,052.00 2,827.00 3,192.00 3,559.00 3,915.00 4,259.00 23,500.00 2,053.00 2,828.00 3,193.00 3,561.00 3,917.00 4,262.00 23,550.00 2,055.00 2,830.00 3,195.00 3,563.00 3,919.00 4,264.00 23,600.00 2,056.00 2,832.00 3,197.00 3,565.00 3,922.00 4,267.00 23,650.00 2,058.00 2,834.00 3,199.00 3,567.00 3,924.00 4,269.00 23,700.00 2,059.00 2,836.00 3,201.00 3,569.00 3,926.00 4,272.00 23,750.00 2,061.00 2838.00 3,203.00 3,571.00 3,929.00 4,274.00 23,800.00 2,062.00 2,840.00 3,204.00 3,573.00 3,931.00 4,277.00 23,850.00 2,063.00 2,841.00 3,206.00 3,575.00 3,933.00 4,279.00 23,900.00 2,065.00 2,843.00 3,208.00 3,577.00 3,935.00 4,282.00 23,950.00 2,066.00 2,845.00 3,210.00 3,579.00 3,938.00 4,284.00 24,000.00 2,068.00 2,847.00 3,212.00 3,581.00 3,940.00 4,287.00 24,050.00 2,069.00 2,849.00 3,214.00 3,583.00 3,942.00 4,289.00 24,100.00 2,070.00 2,851.00 3,216.00 3,585.00 3,945.00 4,292.00 24,150.00 2,072.00 2,852.00 3,217.00 3,587.00 3,947.00 4,294.00 24,200.00 2,073.00 2,854.00 3,219.00 3,589.00 3,949.00 4,297.00 24,250.00 2,075.00 2,856.00 3,221.00 3,592.00 3,951.00 4,299.00 24,300.00 2,076.00 2,858.00 3,223.00 3,594.00 3,954.00 4,302.00 24,350.00 2,077.00 2,860.00 3,225.00 3,596.00 3,956.00 4,304.00 24,400.00 2,079.00 2,862.00 3,227.00 3,598.00 3,958.00 4,307.00 24,450.00 2,080.00 2,864.00 3,228.00 3,600.00 3,961.00 4,309.00 24,500.00 2,082.00 2,865.00 3,230.00 3,602.00 3,963.00 4,312.00 24,550.00 2,083.00 2,867.00 3,232.00 3,604.00 3,965.00 4,314.00 24,600.00 2,085.00 2,869.00 3,234.00 3,606.00 3,967.00 4,317.00 24,650.00 2,086.00 2,871.00 3,236.00 3,608.00 3,970.00 4,319.00 24,700.00 2,087.00 2,873.00 3,238.00 3,610.00 3,972.00 4,322.00 24,750.00 2,089.00 2,875.00 3,240.00 3,612.00 3,974.00 4,324.00 24,800.00 2,090.00 2,876.00 3,241.00 3,614.00 3,977.00 4,326.00 24,850.00 2,092.00 2,878.00 3,243.00 3,616.00 3,979.00 4,329.00 24,900.00 2,093.00 2,880.00 3,245.00 3,618.00 3,981.00 4,331.00 24,950.00 2,094.00 2,882.00 3,247.00 3,620.00 3,983.00 4,334.00 25,000.00 2,096.00 2,884.00 3,249.00 3,622.00 3,986.00 4,336.00 25,050.00 2,097.00 2,886.00 3,251.00 3,624.00 3,988.00 4,339.00 25,100.00 2,099.00 2,887.00 3,252.00 3,626.00 3,990.00 4,341.00 25,150.00 2,100.00 2,889.00 3,254.00 3,629.00 3,993.00 4,344.00 25,200.00 2,102.00 2,891.00 3,256.00 3,631.00 3,995.00 4,346.00 25,250.00 2,103.00 2,893.00 3,258.00 3,633.00 3,997.00 4,349.00 25,300.00 2,104.00 2,895.00 3,260.00 3,635.00 3,999.00 4,351.00 25,350.00 2,106.00 2,897.00 3,262.00 3,637.00 4,002.00 4,354.00 25,400.00 2,107.00 2,899.00 3,264.00 3,639.00 4,004.00 4,356.00 25,450.00 2,109.00 2,900.00 3,265.00 3,641.00 4,006.00 4,359.00 25,500.00 2,110.00 2,902.00 3,267.00 3,643.00 4,009.00 4,361.00 25,550.00 2,111.00 2,904.00 3,269.00 3,645.00 4,011.00 4,364.00 25,600.00 2,113.00 2,906.00 3,271.00 3,647.00 4,013.00 4,366.00 25,650.00 2,114.00 2,908.00 3,273.00 3,649.00 4,015.00 4,369.00 25,700.00 2,116.00 2,910.00 3,275.00 3,651.00 4,018.00 4,371.00 25,750.00 2,117.00 2,911.00 3,276.00 3,653.00 4,020.00 4,374.00 25,800.00 2,119.00 2,913.00 3,278.00 3,655.00 4,022.00 4,376.00 25,850.00 2,120.00 2,915.00 3,280.00 3,657.00 4,024.00 4,379.00 25,900.00 2,121.00 2,917.00 3,282.00 3,659.00 4,027.00 4,381.00 25,950.00 2,123.00 2,919.00 3,284.00 3,661.00 4,029.00 4,384.00 26,000.00 2,124.00 2,921.00 3,286.00 3,663.00 4,031.00 4,386.00 26,050.00 2,126.00 2,923.00 3,287.00 3,666.00 4,034.00 4,389.00 26,100.00 2,127.00 2,924.00 3,289.00 3,668.00 4,036.00 4,391.00 26,150.00 2,128.00 2,926.00 3,291.00 3,670.00 4,038.00 4,394.00 26,200.00 2,130.00 2,928.00 3,293.00 3,672.00 4,040.00 4,396.00 26,250.00 2,131.00 2,930.00 3,295.00 3,674.00 4,043.00 4,399.00 26,300.00 2,133.00 2,932.00 3,297.00 3,676.00 4,045.00 4,401.00 26,350.00 2,134.00 2,934.00 3,299.00 3,678.00 4,047.00 4,403.00 26,400.00 2,136.00 2,935.00 3,300.00 3,680.00 4,050.00 4,406.00 26,450.00 2,137.00 2,937.00 3,302.00 3,682.00 4,052.00 4,408.00 26,500.00 2,138.00 2,939.00 3,304.00 3,684.00 4,054.00 4,411.00 26,550.00 2,140.00 2,941.00 3,306.00 3,686.00 4,056.00 4,413.00 26,600.00 2,141.00 2,943.00 3,308.00 3,688.00 4,059.00 4,416.00 26,650.00 2,143.00 2,945.00 3,310.00 3,690.00 4,061.00 4,418.00 26,700.00 2,144.00 2,947.00 3,311.00 3,692.00 4,063.00 4,421.00 26,750.00 2,145.00 2,948.00 3,313.00 3,694.00 4,066.00 4,423.00 26,800.00 2,147.00 2,950.00 3,315.00 3,696.00 4,068.00 4,426.00 26,850.00 2,148.00 2,952.00 3,317.00 3,698.00 4,070.00 4,428.00 26,900.00 2,150.00 2,954.00 3,319.00 3,701.00 4,072.00 4,431.00 26,950.00 2,151.00 2,956.00 3,321.00 3,703.00 4,075.00 4,433.00 27,000.00 2,153.00 2,958.00 3,323.00 3,705.00 4,077.00 4,436.00 27,050.00 2,154.00 2,959.00 3,324.00 3,707.00 4,079.00 4,438.00 27,100.00 2,155.00 2,961.00 3,326.00 3,709.00 4,082.00 4,441.00 27,150.00 2,157.00 2,963.00 3,328.00 3,711.00 4,084.00 4,443.00 27,200.00 2,158.00 2,965.00 3,330.00 3,713.00 4,086.00 4,446.00 27,250.00 2,160.00 2,967.00 3,332.00 3,715.00 4,088.00 4,448.00 27,300.00 2,161.00 2,969.00 3,334.00 3,717.00 4,091.00 4,451.00 27,350.00 2,162.00 2,970.00 3,335.00 3,719.00 4,093.00 4,453.00 27,400.00 2,164.00 2,972.00 3,337.00 3,721.00 4,095.00 4,456.00 27,450.00 2,165.00 2,974.00 3,339.00 3,723.00 4,098.00 4,458.00 27,500.00 2,167.00 2,976.00 3,341.00 3,725.00 4,100.00 4,461.00 27,550.00 2,168.00 2,978.00 3,343.00 3,727.00 4,102.00 4,463.00 27,600.00 2,170.00 2,980.00 3,345.00 3,729.00 4,104.00 4,466.00 27,650.00 2,171.00 2,982.00 3,347.00 3,731.00 4,107.00 4,468.00 27,700.00 2172.00 2,983.00 3,348.00 3,733.00 4,109.00 4,471.00 27,750.00 2,174.00 2,985.00 3,350.00 3,735.00 4,111.00 4,473.00 27,800.00 2,175.00 2,987.00 3,352.00 3,738.00 4,114.00 4,475.00 27,850.00 2,177.00 2,989.00 3,354.00 3,740.00 4,116.00 4,478.00 27,900.00 2,178.00 2,991.00 3,356.00 3,742.00 4,118.00 4,480.00 27,950.00 2,179.00 2,993.00 3,357.00 3,744.00 4,120.00 4,483.00 28,000.00 2,181.00 2,994.00 3,359.00 3,746.00 4,122.00 4,485.00 28,050.00 2,182.00 2,996.00 3,361.00 3,748.00 4,125.00 4,488.00 28,100.00 2,184.00 2,998.00 3,363.00 3,750.00 4,127.00 4,490.00 28,150.00 2,185.00 3,000.00 3,365.00 3,752.00 4,129.00 4,492.00 28,200.00 2,186.00 3,001.00 3,366.00 3,754.00 4,131.00 4,495.00 28,250.00 2,188.00 3,003.00 3,368.00 3,756.00 4,133.00 4,497.00 28,300.00 2,189.00 3,005.00 3,370.00 3,758.00 4,136.00 4,500.00 28,350.00 2,190.00 3,007.00 3,372.00 3,759.00 4,138.00 4,502.00 28,400.00 2,192.00 3,009.00 3,374.00 3,761.00 4,140.00 4,504.00 28,450.00 2,193.00 3,010.00 3,375.00 3,763.00 4,142.00 4,507.00 28,500.00 2,194.00 3,012.00 3,377.00 3,765.00 4,145.00 4,509.00 28,550.00 2,196.00 3,014.00 3,379.00 3,767.00 4,147.00 4,512.00 28,600.00 2,197.00 3,016.00 3,381.00 3,769.00 4,149.00 4,514.00 28,650.00 2,199.00 3,017.00 3,382.00 3,771.00 4,151.00 4,516.00 28,700.00 2,200.00 3,019.00 3,384.00 3,773.00 4,153.00 4,519.00 28,750.00 2,201.00 3,021.00 3,386.00 3,775.00 4,156.00 4,521.00 28,800.00 2,203.00 3,023.00 3,388.00 3,777.00 4,158.00 4,524.00 28,850.00 2,204.00 3,025.00 3,390.00 3,779.00 4,160.00 4,526.00 28,900.00 2,205.00 3,026.00 3,391.00 3,781.00 4,162.00 4,528.00 28,950.00 2,207.00 3,028.00 3,393.00 3,783.00 4,164.00 4,531.00 29,000.00 2,208.00 3,030.00 3,395.00 3,785.00 4,167.00 4,533.00 29,050.00 2,210.00 3,032.00 3,397.00 3,787.00 4,169.00 4,536.00 29,100.00 2,211.00 3,034.00 3,398.00 3,789.00 4,171.00 4,538.00 29,150.00 2,212.00 3,035.00 3,400.00 3,791.00 4,173.00 4,540.00 29,200.00 2,214.00 3,037.00 3,402.00 3,793.00 4,175.00 4,543.00 29,250.00 2,215.00 3,039.00 3,404.00 3,795.00 4,178.00 4,545.00 29,300.00 2,216.00 3,041.00 3,406.00 3,797.00 4,180.00 4,548.00 29,350.00 2,218.00 3,042.00 3,407.00 3,799.00 4,182.00 4,550.00 29,400.00 2,219.00 3,044.00 3,409.00 3,801.00 4,184.00 4,552.00 29,450.00 2,220.00 3,046.00 3,411.00 3,803.00 4,186.00 4,555.00 29,500.00 2,222.00 3,048.00 3,413.00 3,805.00 4,189.00 4,557.00 29,550.00 2,223.00 3,050.00 3,415.00 3,807.00 4,191.00 4,560.00 29,600.00 2,225.00 3,051.00 3,416.00 3,809.00 4,193.00 4,562.00 29,650.00 2,226.00 3,053.00 3,418.00 3,811.00 4,195.00 4,564.00 29,700.00 2,227.00 3,055.00 3,420.00 3,813.00 4,197.00 4,567.00 29,750.00 2,229.00 3,057.00 3,422.00 3,815.00 4,200.00 4,569.00 29,800.00 2,230.00 3,058.00 3,423.00 3,817.00 4,202.00 4,572.00 29,850.00 2,231.00 3,060.00 3,425.00 3,819.00 4,204.00 4,574.00 29,900.00 2,233.00 3,062.00 3,427.00 3,821.00 4,206.00 4,576.00 29,950.00 2,234.00 3,064.00 3,429.00 3,823.00 4,208.00 4,579.00 30,000.00 2,236.00 3,066.00 3,431.00 3,825.00 4,211.00 4,581.00

(Ga. L. 1870, p. 413, § 2; Code 1873, § 1742; Code 1882, § 1742; Civil Code 1895, § 2462; Civil Code 1910, § 2981; Code 1933, § 30-207; Ga. L. 1979, p. 466, § 12; Ga. L. 1989, p. 861, § 1; Ga. L. 1991, p. 94, § 19; Ga. L. 1992, p. 1833, § 1; Ga. L. 1994, p. 1728, § 1; Ga. L. 1995, p. 603, § 2; Ga. L. 1996, p. 453, § 6; Ga. L. 2005, p. 224, § 5/HB 221; Ga. L. 2006, p. 72, § 19/SB 465; Ga. L. 2006, p. 583, § 4/SB 382; Ga. L. 2007, p. 47, § 19/SB 103; Ga. L. 2008, p. 272, §§ 1-9/SB 483; Ga. L. 2009, p. 96, §§ 1-6/HB 145; Ga. L. 2009, p. 453, § 2-2/HB 228; Ga. L. 2010, p. 878, § 19/HB 1387; Ga. L. 2011, p. 550, § 1/SB 115; Ga. L. 2014, p. 457, §§ 1-8/SB 282; Ga. L. 2017, p. 646, §§ 1-3 - 1-8, 3-1/SB 137; Ga. L. 2018, p. 937, §§ 1-1, 1-1A - 1-1C, 1-2 - 1-4, 1-4A, 1-5/SB 427; Ga. L. 2019, p. 636, §§ 1-8/HB 381; Ga. L. 2019, p. 711, § 5/HB 481; Ga. L. 2020, p. 493, § 19/SB 429.)

The 2017 amendment, effective July 1, 2017, substituted the present provisions of paragraph (a)(6.1) for the former provisions, which read: "'Child support services' means the agency within the Department of Human Services which provides and administers child support services."; deleted "and" at the end of paragraph (b)(10), substituted "; and" for the period at the end of paragraph (b)(11), and added paragraph (b)(12); in subparagraph (c)(2)(A), inserted ", the duration of such support," near the beginning, and added "or multiple worksheets when there is more than one minor child" immediately preceding the semicolon at the end; deleted "as required by Code Section 19-5-12" following "Specify" in subparagraph (c)(2)(B); substituted "each parent's" for "the parent's" in subparagraph (c)(2)(C); designated the existing provisions of subparagraph (h)(1)(F) as division (h)(1)(F)(i), and substituted "the final child support order" for "written order of the court" at the end, and added division (h)(1)(F)(ii); in division (i)(2)(K)(i), in the last sentence, substituted "the child residing" for "or when the child resides", and added ", or visitation rights not being utilized" immediately preceding the period at the end; deleted "and be treated as a deduction" following "deviations" immediately preceding the period at the end of division (i)(2)(K)(ii); substituted "separately by each custodial parent for each child for whom such parent is the custodial parent" for "separately for the child for whom the father is the custodial parent and for the child for whom the mother is the custodial parent" in the first sentence of the introductory language of subsection (l); and, in paragraph (m)(1), in the last sentence, substituted "worksheets and any schedule that was prepared for the purpose of calculating the amount of child support" for "worksheet and, if there are any deviations, Schedule E" near the middle, and substituted "worksheets and schedules" for "worksheet and schedule" near the end.

The 2018 amendment, effective July 1, 2018, throughout this Code section, substituted "support amount" for "support order" and deleted "child support" preceding "order"; substituted the present provisions of paragraph (b)(12) for the former provisions, which read: "When there is more than one child for whom support is being determined, the court shall establish the amount of support and the duration of such support in accordance with subsection (e) of this Code section. Separate worksheets shall be utilized for such determination and shall be attached to the final child support order. Such order shall contain findings as required by law."; added the second and third sentences of subsection (d); in subparagraph (f)(4)(A), substituted "may be imputed" for "shall be determined by imputing gross income based on a 40 hour workweek at minimum wage" at the end of the first sentence, and added the second and third sentences; inserted "impute income as set forth in subparagraph (A) of this paragraph, or may" in the middle of subparagraph (f)(4)(B); added the third sentence of subparagraph (f)(4)(D); substituted the present provisions of division (h)(2)(B)(iii) for the former provisions, which read: "Eligibility for or enrollment of the child in Medicaid or PeachCare for Kids Program shall not satisfy the requirement that the final child support order provide for the child's health care needs. Health coverage through PeachCare for Kids Program and Medicaid shall not prevent a court from ordering either or both parents to obtain other health insurance."; deleted "the" preceding "uninsured health care" three times in subparagraph (h)(3)(A); in subparagraph (i)(1)(A), deleted "primary" following "child support," in the second sentence, and added "as well as a noncustodial parent's ability or inability to pay the presumptive amount of child support" at the end of the third sentence; in division (i)(2)(B)(iii), inserted "the noncustodial parent's basic subsistence needs and", inserted "of his or her", and deleted "of the noncustodial parent" following "reasonable expenses"; in subparagraph (i)(2)(J), in the third sentence, substituted "such expense" for "the expense" and deleted "calculation of the" following "considered in the"; and inserted "becomes incarcerated," in the middle of the first sentence of paragraph (j)(1).

The 2019 amendments. The first 2019 amendment, effective July 1, 2019, throughout this Code section, inserted "or the jury", substituted "When" for "Where", substituted "when" for "where", inserted "the", and substituted "child-rearing" for "child rearing"; inserted "set forth" in paragraph (a)(6); substituted "who" for "that" in the undesignated language following paragraph (a)(20); substituted "Who" for "That" at the beginning of subparagraph (a)(20)(B); substituted "children as calculated" for "children calculated as set forth" in the middle of paragraph (a)(22); substituted "such" for "these" in the middle of the first sentence of subsection (d) and in the middle of division (i)(2)(J)(ii); in subparagraph (f)(2)(C), substituted "child-placing" for "child placing" in the middle and deleted "and" at the end; added "; and" at the end of subparagraph (f)(2)(D); added subparagraph (f)(2)(E); substituted "as provided for in subparagraph (f)(4)(A) of this Code section" for "pursuant to a determination that gross income for the current year is based on a 40 hour workweek at minimum wage" at the end of subdivision (f)(4)(D)(vi)(IV); added "of this Code section" at the end of division (f)(5)(B)(i); inserted "the" preceding "jury" in division (b)(1)(F)(ii); and inserted commas following "jury may" and "interrogatory" in the middle of subparagraph (i)(2)(F). The second 2019 amendment, effective January 1, 2020, substituted "Reserved" for " 'Child' means child or children" in paragraph (a)(4); and added subsection (a.1).

The 2020 amendment, effective July 29, 2020, part of an Act to revise, modernize, and correct the Code, revised punctuation in division (f)(1)(A)(vii).

- Collection of support payments by child support receivers, T. 15, C. 15.

Temporary order of support pending paternity determination, § 19-7-46.2.

- The amendment of this Code section by Ga. L. 2006, p. 72, § 19, irreconcilably conflicted with and was treated as superseded by Ga. L. 2006, p. 583, § 4. See County of Butts v. Strahan, 151 Ga. 417 (1921).

- Ga. L. 1979, p. 466, § 12 amended the prior version of this Code section to provide that either parent may be liable for child support. Cases decided prior to the 1979 enactment appear to remain valid except insofar as they may imply that the father only may be liable for such support.

Ga. L. 1995, p. 603, § 4, not codified by the General Assembly, provides that it is the intention of Sections 1 and 2 of that Act to encourage judges in divorce cases to require all couples involved in contested divorces to go to mediation to attempt a mutually agreeable settlement.

Ga. L. 2005, p. 224, § 1/HB 221, not codified by the General Assembly, provides that: "The General Assembly finds and declares that it is important to assess periodically child support guidelines and determine whether existing guidelines continue to be viable and effective or whether they have failed or ceased to accomplish their original policy objectives. The General Assembly further finds that supporting Georgia's children is vitally important to the citizens of Georgia. Therefore, the General Assembly has determined that it is in the best interests of the state and its citizenry to undertake an evaluation of the child support guidelines on a continuing basis. The General Assembly declares that it is important that all of Georgia's children are provided with adequate financial support whether the children's parents are living together or not living together. The General Assembly finds that both parents have a continuing obligation with respect to providing financial and emotional stability for their child or children. It is the hope of the members of the General Assembly that all parents work together to advance the best interest of their children."

Ga. L. 2006, p. 583, § 10(b)/SB 382, not codified by the General Assembly, provides: "Sections 1 through 7 of this Act shall become effective on January 1, 2007, and shall apply to all pending civil actions on or after January 1, 2007."

Ga. L. 2019, p. 636, §§ 4, 5, 6, and 8/HB 381, purported to amend subparagraph (f)(5)(C), subparagraphs (h)(1)(A) and (h)(1)(D), subparagraph (i)(2)(K), and subsection (n), respectively, but actually made no revisions.

Ga. L. 2019, p. 711, § 1/HB 481, not codified by the General Assembly, provides: "This Act shall be known and may be cited as the 'Living Infants Fairness and Equality (LIFE) Act.'"

Ga. L. 2019, p. 711, § 2/HB 481, not codified by the General Assembly, provides: "The General Assembly of Georgia makes the following findings:

"(1) In the founding of the United States of America, the State of Georgia and the several states affirmed that: 'We hold these Truths to be self-evident, that all Men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty, and the Pursuit of Happiness - that to secure these Rights, Governments are instituted among men;'

"(2) To protect the fundamental rights of all persons, and specifically to protect the fundamental rights of particular classes of persons who had not previously been recognized under law, the 14th Amendment to the United States Constitution was ratified, providing that, 'nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny any person within its jurisdiction the equal protection of the laws';

"(3) Modern medical science, not available decades ago, demonstrates that unborn children are a class of living, distinct persons and more expansive state recognition of unborn children as persons did not exist when Planned Parenthood v. Casey (1992) and Roe v. Wade (1973) established abortion related precedents;

"(4) The State of Georgia, applying reasoned judgment to the full body of modern medical science, recognizes the benefits of providing full legal recognition to an unborn child above the minimum requirements of federal law;

"(5) Article I, Section I, Paragraphs I and II of the Constitution of the State of Georgia affirm that '[n]o person shall be deprived of life, liberty, or property except by due process of law'; and that '[p]rotection to person and property is the paramount duty of government and shall be impartial and complete. No person shall be denied the equal protection of the laws'; and

"(6) It shall be the policy of the State of Georgia to recognize unborn children as natural persons."

Ga. L. 2019, p. 711, § 13/HB 481, not codified by the General Assembly, provides: "Any citizen of this state shall have standing and the right to intervene and defend in any action challenging the constitutionality of any portion of this Act."

Ga. L. 2019, p. 711, § 14/HB 481, not codified by the General Assembly, provides: "All provisions of this Act shall be severable in accordance with Code Section 1-1-3."

- Title II of the federal Social Security Act, referred to in division (f)(1)(A)(xiii), and subparagraphs (f)(3)(A) and (f)(3)(D) is codified at 42 U.S.C. § 401 et seq. Title IV-A of the federal Social Security Act, referred to in division (f)(2)(B)(i), is codified at 42 U.S.C. § 601 et seq. Title IV-D of the federal Social Security Act, referred to in subparagraph (k)(3)(C), is codified at 42 U.S.C. § 651 et seq. Title XVI of the federal Social Security Act, referred to in division (f)(2)(B)(iii), is codified at 42 U.S.C. § 1381 et seq. Section 402(d) of the federal Social Security Act, referred to in division (f)(2)(B)(iv), is codified at 42 U.S.C. § 602.

- Periodic review and modification of child support obligations, Official Compilation of the Rules and Regulations of the State of Georgia, Office of Child Support Recovery, Recovery and administration of child support, § 290-7-1-.06.

- For article, "Tax Aspects of Divorce and Separation and the Innocent Spouse Rules," see 3 Ga. St. U.L. Rev. 201 (1987). For article, "Alimony and Child Support: Limit Issuance or Renewal of Licenses for Failure to Comply with Child Support Order," see 13 Ga. St. U.L. Rev. 127 (1996). For annual survey article discussing developments in domestic relations law, see 52 Mercer L. Rev. 213 (2000). For article, "Why Georgia's Child Support Guidelines Are Unconstitutional," see 6 Ga. St. B.J. 8 (2000). For article, "Constitutionally Sound Objectives and Means," see 6 Ga. St. B.J. 16 (2000). For survey article on domestic relations cases, see 55 Mercer L. Rev. 223 (2003). For annual survey of domestic relations law, see 56 Mercer L. Rev. 221 (2004). For article on 2005 amendment of this Code section, see 22 Ga. St. U.L. Rev. 73 (2005). For annual survey of domestic relations cases, see 57 Mercer L. Rev. 173 (2005). For article, "Georgia's Child Support Guidelines: Effective January 1, 2007," see 12 Ga. St. B.J. 12 (2006). For annual survey of domestic relations law, see 58 Mercer L. Rev. 133 (2006). For article on 2006 amendment of this Code section, see 23 Ga. St. U.L. Rev. 103 (2006). For survey article on domestic relations law, see 59 Mercer L. Rev. 139 (2007). For survey article on domestic relations law, see 60 Mercer L. Rev. 121 (2008). For annual survey on domestic relations, see 61 Mercer L. Rev. 117 (2009). For annual survey of law on domestic relations, see 62 Mercer L. Rev. 105 (2010). For annual survey on domestic relations law, see 64 Mercer L. Rev. 121 (2012). For annual survey on domestic relations, see 65 Mercer L. Rev. 107 (2013). For article on domestic relations, see 66 Mercer L. Rev. 65 (2014). For annual survey of domestic relations law, see 67 Mercer L. Rev. 47 (2015). For annual survey on domestic relations, see 69 Mercer L. Rev. 83 (2017). For annual survey on domestic relations, see 70 Mercer L. Rev. 81 (2018). For article on the 2019 amendment of this Code section, see 36 Ga. St. U.L. Rev. 155 (2019). For annual survey on domestic relations, see 71 Mercer L. Rev. 83 (2019). For note discussing Georgia's child support laws, their problems, and some proposed solutions, see 11 Ga. L. Rev. 387 (1977). For note on 1989 amendment to this Code section, see 6 Ga. St. U.L. Rev. 227 (1989). For note on 1992 amendment of this Code section, see 9 Ga. St. U.L. Rev. 234 (1992). For note on the 1994 amendment of this Code section, see 11 Ga. St. U.L. Rev. 171 (1994).

ANALYSIS

• General Consideration
• Role of Jury
• Modification of Award
• Writing Requirement
• Education of Children

Purpose of statute was to relieve father of common-law liability to support minor children, and substitute therefor a liability by virtue of a court decree. Thomas v. Holt, 209 Ga. 133, 70 S.E.2d 595 (1952); Booker v. Booker, 219 Ga. 358, 133 S.E.2d 353 (1963).

Purpose of statute was to substitute for a father's common-law liability to support his children a liability by virtue of a court decree, whereby he is required to contribute a specified amount at fixed intervals. Clark v. Clark, 228 Ga. 838, 188 S.E.2d 487 (1972); Newsome v. Newsome, 237 Ga. 221, 227 S.E.2d 347 (1976).

- Statutory child support guidelines under O.C.G.A. § 19-6-15 were not unconstitutionally violative of the constitutional guarantees of due process, equal protection, and privacy, when inherent classifications and distinctions therein were required in order to ensure fairness and equity between the parents and that the welfare of the children were protected; a rational basis existed to ensure that adequate support was provided for Georgia's children whose parents have divorced or separated. Ga. Dep't of Human Res. v. Sweat, 276 Ga. 627, 580 S.E.2d 206, cert. denied, 540 U.S. 966, 124 S. Ct. 432, 157 L. Ed. 2d 310 (2003).

O.C.G.A. § 19-6-15 is not unconstitutional under the Supremacy Clause. Ward v. McFall, 277 Ga. 649, 593 S.E.2d 340, cert. denied, 543 U.S. 818, 125 S. Ct. 57, 160 L. Ed. 2d 26 (2004).

- Plain language of subsection (f) of O.C.G.A. § 19-6-15 precludes a divorce decree entered before July 1, 1992, from being modified under subsections (e) and (f). Honey v. Honey, 263 Ga. 722, 438 S.E.2d 87 (1994).

Plain language of subsection (f) of O.C.G.A. § 19-6-15 itself precludes a divorce decree intended before July 1, 1992, from being modified under subsections (e) and (f). Cote v. Waldrop, 263 Ga. 752, 438 S.E.2d 630 (1994).

- Trial court's nunc pro tunc order, referencing the court's original order dated before the effective date of the 2005 amendment to O.C.G.A. § 19-6-15, was held to have not actually applied to the amended statute as the appellant failed to show otherwise through evidence contained in the record on appeal. Sebby v. Costo, 290 Ga. App. 61, 658 S.E.2d 830 (2008).

§ 19-6-19(a). - In an action to modify child support, the computational reference of subsection (b) of O.C.G.A. § 19-6-15 may be applied only after the finder of fact first finds that the requirements of O.C.G.A. § 19-6-19(a) have been satisfied. Willingham v. Willingham, 216 Ga. 674, 410 S.E.2d 98 (1991).

Construction with O.C.G.A. § 19-5-12. - Although a spouse alleged on appeal that a motion to set aside that portion of the divorce decree which dealt with the issue of child support, which incorporated the parties' settlement agreement, was properly granted because the decree failed to set forth a specific baseline dollar amount for child support, as required by O.C.G.A. § 19-5-12, the decree contained stated dollar amounts which could be considered baseline payments; hence, pursuant to O.C.G.A. § 19-6-15 as applicable at the time, the trial court properly found that the spouse was liable for paying child support for two children in the range of 23 to 28 percent of the spouse's gross income. Scott v. Scott, 282 Ga. 36, 644 S.E.2d 842 (2007).

- Statutory framework for establishing child support obligations is set forth in O.C.G.A. § 19-6-15, and paragraph (k)(1) provides that a parent may seek a modification of a prior child support decision when there is a substantial change in either parent's income and financial status or the needs of the child. Stoddard v. Meyer, 291 Ga. 739, 732 S.E.2d 439 (2012).

O.C.G.A. § 19-6-15(f)(4)(B), which applied only in child support modification actions, was intended to be permissive, rather than mandatory, in nature, thus, if the conditions precedent were satisfied the trial court could, but was not required to, use the prescribed formula as a proxy for missing evidence regarding a parent's income. Jackson v. Sanders, 299 Ga. 332, 788 S.E.2d 387 (2016).

- Guidelines for computing the amount of child support found in O.C.G.A. § 19-6-15(b) and (c), known as the "Child Support Guidelines," are the expression of the legislative will regarding the calculation of child support and must be considered by any court setting the child support. Pruitt v. Lindsey, 261 Ga. 540, 407 S.E.2d 750 (1991).

- Trial court abused the court's discretion in calculating child support without determining the mother's gross income. Gordy v. Gordy, 246 Ga. App. 802, 542 S.E.2d 536 (2000).

While the trial court's failure to identify every fact that could qualify as a special circumstance under O.C.G.A. § 19-6-15(c) was not error per se: (1) the court failed to actually consider whether ordering a parent to pay 20 percent of that parent's gross income each month was excessive when coupled with other financial obligations under the order; (2) no evidence existed as to the actual future costs of the parent's additional financial obligations under the order, nor did the court place any limitations on how much the parent would be required to pay toward these expenses; and (3) the court made no written findings as to whether the parent had the financial resources to pay these obligations in addition to the child support obligation. Hence, the court's order was vacated, and the matter was remanded for the trial court to make an express determination of whether the parent's presumptive child support amount was excessive under the circumstances presented, and, if so, to reduce the presumptive amount accordingly. Weil v. Paseka, 282 Ga. App. 403, 638 S.E.2d 833 (2006).

O.C.G.A. § 19-6-15(c)(6) does not limit the support obligations to current obligations to minor children. Betty v. Betty, 274 Ga. 194, 552 S.E.2d 846 (2001).

Under O.C.G.A. § 19-6-15(c)(6), a trial court was permitted to deviate from the child support guidelines set forth under § 19-6-15(b) if a trial court found that a party's support obligations to another household made the presumptive amount of support either excessive or inadequate; the mere fact of additional children did not justify a reduction in the guideline range. Betty v. Betty, 274 Ga. 194, 552 S.E.2d 846 (2001).

- Trial court did not err in ordering a husband to pay his entire child support obligation for the next 13 years in a single payment because nothing in the child support guidelines statute, O.C.G.A. § 19-6-15, expressly precluded lump-sum child support awards; the statute as amended explicitly authorizes trial courts to exercise discretion in setting the manner and timing of payment, and the language of § 19-6-15(c)(2)(B), which requires trial courts to specify in what manner, how often, to whom, and until when the support shall be paid is certainly broad enough to encompass an order to pay a child support obligation all at once. Mullin v. Roy, 287 Ga. 810, 700 S.E.2d 370 (2010).

- Consideration of the existence of a second child in calculating the level-of-support payment was proper, although the order was for only one child, the subject of a paternity suit, in which suit the other child was not involved; the legislature intended that the trial courts would consider the totality of the circumstances in setting the level of support, and not be bound by the recommended guidelines. Batterson v. Groves, 204 Ga. App. 52, 418 S.E.2d 373, cert. denied, 204 Ga. App. 921, 418 S.E.2d 373 (1992).

- It would not be improper to use the guidelines for computation of a child support award in civil proceedings as a condition in a criminal abandonment action since the child support award is neither a part of the sentence nor a punishment. Vogel v. State, 196 Ga. App. 514, 396 S.E.2d 262 (1990).

- Georgia General Assembly has not specified that only noncustodial parents are to pay child support. Williamson v. Williamson, 293 Ga. 721, 748 S.E.2d 679 (2013).

Legislature did not specify that only noncustodial parents are to pay child support. James v. James, 246 Ga. 233, 271 S.E.2d 151 (1980).

- Trial court's express finding about the father's income at the time the father and mother divorced should have been used to determine whether the father's income had changed significantly in the five years between entry of the parties' divorce decree and the mother's filing of a petition to modify the father's child support obligation; thus, the trial court erred by not using that express finding, but instead using the father's tax returns that showed the father earned significantly more income around the time the divorce decree was entered than was reflected in the divorce decree's finding. Hulett v. Sutherland, 276 Ga. 596, 581 S.E.2d 11 (2003).

By law, father was responsible for support of his minor children and this may include providing for their education. Collins v. Collins, 231 Ga. 683, 203 S.E.2d 524 (1974).

There is no legal requirement that father support his children once they reach majority. Newton v. Newton, 222 Ga. 175, 149 S.E.2d 128 (1966) (decided prior to the 1992 amendment, which added subsections (e) and (f)).

Requirement to provide support beyond age of majority may not, as matter of law, be imposed. Clavin v. Clavin, 238 Ga. 421, 233 S.E.2d 151 (1977); Coleman v. Coleman, 240 Ga. 417, 240 S.E.2d 870 (1977) (decided prior to the 1992 amendment, which added subsections (e) and (f)).

- To the extent that Adame v. Herndandez, 327 Ga. App. 869 (2014) holds that the trial court must support with written findings the court's exercise of discretion and consideration of the best interest of the child for whom child support is being awarded when applying a theoretical child support order under O.C.G.A. § 19-6-15(f)(5)(C), that decision is hereby overruled. Neal v. Hibbard, 296 Ga. 882, 770 S.E.2d 600 (2015).

Children are entitled to be supported commensurate with their proven customary needs and the father's financial ability to provide for them. Clavin v. Clavin, 238 Ga. 421, 233 S.E.2d 151 (1977).

Father cannot provide bare subsistence existence for his children and consider that he has done his duty; his support, as far as he is able, must be appropriate to the children's situation. Clavin v. Clavin, 238 Ga. 421, 233 S.E.2d 151 (1977).

Father's duty to provide support and maintenance for minor children does not cease with former wife's remarriage. Vereen v. Arp, 237 Ga. 241, 227 S.E.2d 331 (1976).

- Trial court erred in failing to issue an award establishing the defendant's obligation for future child support when by the defendant's failure to file a timely answer, the defendant admitted the allegation in Georgia Department of Human Resources (DHR's) petition that the defendant was obligated to provide for the future support of the defendant's minor child as the defendant's ability permitted. Department of Human Resources v. Hedgepath, 204 Ga. App. 755, 420 S.E.2d 638 (1992).

- Requirement in an order modifying a final judgment and decree of divorce that the former spouses alternate years in paying for their children's clothing, uniforms, school fees, and similar items was not improperly vague and indefinite; the inherent uncertainty of the future expenses of the children did not, at the time of the award, show that the award departed from the statutory guidelines. Facey v. Facey, 281 Ga. 367, 638 S.E.2d 273 (2006).

- Trial court did not err in the amount of the child support obligation that the court bestowed upon the mother when the father was given custody of the children because the mere possibility of the parties' children incurring amounts of uninsured medical expenses and uninsured counseling expenses so as to constitute extraordinary medical costs was not sufficient at that juncture to support a finding that the award of child support departed from the Georgia Child Support Guidelines. Moon v. Moon, 277 Ga. 375, 589 S.E.2d 76 (2003).

- Trial court erred in failing to require the parties to share uninsured medical expenses for the minor child because both parents were required to be responsible for such expenses and the trial court was required to include provisions for payment of such expenses in the court's order. Moore v. McKinney, 335 Ga. App. 855, 783 S.E.2d 373 (2016).

- Trial court did not abuse the court's discretion in requiring a husband to pay the entire cost of the child's medical insurance and uncovered medical expenses because the child support worksheet incorporated into the trial court's order clearly showed that an adjustment to the presumptive amounts of child support had been made to account for the expense of the premiums for the child's insurance coverage; in accordance with O.C.G.A. § 19-6-15(h)(2)(A), and using the wife's pro rata share of the parties' combined income, 26 percent of the amount of the health insurance premium had been deducted from the husband's basic child support obligation and added to the wife's obligation. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).

- Trial court did not abuse the court's discretion in ordering the husband to reimburse the wife up to $250 per month for work-related childcare expenses instead of allowing the husband to watch the children because the parties' younger child was diagnosed with high-functioning autism and needed some special care; a few times when the younger child was solely in the husband's care, the child wandered off and was left alone in situations where the child could have been hurt; and the wife testified that the children's daycare provided the special care, attention, and consistency the younger child needed while allowing the younger child to stay in the company of the older brother who had a calming effect on the younger child. Sahibzada v. Sahibzada, 294 Ga. 783, 757 S.E.2d 51 (2014).

- Court upheld an increase in child support owed by a mother, finding that the costs of a nanny were reasonable work-related child care expenses for the father, although he worked from home, considering the young age of the children, that the costs of a nanny were small in comparison to the father's monthly income, and the nanny's qualifications. Taylor v. Taylor, 293 Ga. 615, 748 S.E.2d 873 (2013).

- Guidelines for child support established by O.C.G.A. § 19-6-15 provide the best means of estimating the amount of support a child born out of wedlock had a reasonable expectation of receiving from the child's deceased father. In re Adventure Bound Sports, Inc., 858 F. Supp. 1192 (S.D. Ga. 1994).

Child support is part of alimony, and right to receive alimony ceases upon death of husband unless the decree expressly provides to the contrary. Veal v. Veal, 226 Ga. 285, 174 S.E.2d 435 (1970).

With respect to a divorced father and a child support decree, absent some express, voluntary provision in the decree, the decree will not be enforced after the death of the father. Clavin v. Clavin, 238 Ga. 421, 233 S.E.2d 151 (1977).

In making decisions about child support, trial court is charged with considering child's welfare. James v. James, 246 Ga. 233, 271 S.E.2d 151 (1980).

- When the existence and terms of an agreement between the parties are disputed, and the sufficiency of child support is called into question, the record should reflect the trial court's comparison of need and ability to pay and the record should reflect an award that is consistent with that comparison. Arrington v. Arrington, 261 Ga. 547, 407 S.E.2d 758 (1991).

- Evidence showing that the father had a mechanical engineering degree from the University of Alabama and had recently earned sums in excess of $50,000 per year was sufficient to support the trial court's findings as to earning capacity in lieu of a finding of gross income under O.C.G.A. § 19-6-15. Walker v. Walker, 248 Ga. App. 177, 546 S.E.2d 315 (2001).

Earning capacity rather than gross income may be used to determine the amount of child support in certain circumstances, including the absence of any evidence as to actual income. Russ v. Russ, 272 Ga. 438, 530 S.E.2d 469 (2000).

Superior court properly based a child support award on one spouse's earning capacity rather than the income the spouse stated in a financial affidavit when the spouse admitted to making thousands of dollars more than was stated in the affidavit and additional evidence established that the spouse owned a stucco company, that some employees of the company earned more than the income the spouse stated in the affidavit, and that the parties had multiple real estate holdings. Banciu v. Banciu, 282 Ga. 616, 652 S.E.2d 552 (2007).

Trial court did not err in imputing income of $1,100 to a father, although the father was disabled and unemployed; the father represented himself at the trial, could drive, received substantial, unsupervised visitation with his four-year-old daughter, and could obtain family assistance benefits and part-time employment. Larizza v. Larizza, 286 Ga. 461, 689 S.E.2d 306 (2010).

Trial court properly imputed income to the mother when calculating child support because the evidence showed that the mother was making $32,000 and had health insurance available when the mother apparently made the decision to quit a job in Florida and move to Georgia to live with the mother's parents, and there was no evidence that the mother involuntarily left that employment. Caldwell v. Meadows, 312 Ga. App. 70, 717 S.E.2d 668 (2011), overruled on other grounds by Mathenia v. Brumbelow, 2020 Ga. LEXIS 353 (Ga. 2020).

- Because Internal Revenue Service Schedule K-1 income is categorized as self-employment income, O.C.G.A. § 19-6-15(f)(1)(B), that income is not subject to the requirements set forth in § 19-6-15(f)(1)(D) for variable income. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).

- Trial court did not abuse the court's discretion in concluding that the father had failed to present reliable evidence of the father's gross income and, thus, remand was necessary for the trial court to reassess whether to exercise the court's discretion to apply O.C.G.A. § 19-6-15(f)(4)(B), to determine whether to modify the father's child support obligation. Jackson v. Sanders, 299 Ga. 332, 788 S.E.2d 387 (2016).

- Trial court properly found that the term "gross income" in the parties' divorce settlement agreement was ambiguous, and, in construing the agreement against the father as the obligor, that the parties intended for child support to be based on Georgia's Child Support Guidelines, and that, by assigning earned income to the father's professional corporation, thereby substantially understating the father's gross income, the father wilfully violated the conditions of the settlement agreement; the father's "gross income" significantly exceeded Form W-2 wages, and the father's computation of child support based only on the father's Form W-2 salary created a child support deficiency. Pate v. Pate, 280 Ga. 796, 631 S.E.2d 103 (2006).

- Trial court did not err by imputing income of $4,180 per month to a father in addition to the $1,320 in monthly unemployment benefits received based on evaluating the reasonableness of the father's occupational choices, the father's past employment, current assets, current monthly receipts, and self-imposed salary restrictions regarding a job search, which supported a finding that the father was willfully unemployed or underemployed under O.C.G.A. § 19-6-15(f)(4)(D). Friday v. Friday, 294 Ga. 687, 755 S.E.2d 707 (2014).

When considering wilful unemployment or underemployment under O.C.G.A. § 19-6-15(f)(4)(D), the statute does not require a trial court to make written findings as to why it decided to impute income to a spouse. Friday v. Friday, 294 Ga. 687, 755 S.E.2d 707 (2014).

- In modifying a father's child support obligation, the court did not err by imputing income as the court was authorized to consider not only the father's income of record, but also the assets owned, which showed that the father owned four real properties, that the law office practice had declined, a car purchase was made with an attendant monthly payment of $2,036.00, and $2,500.00 per month was being paid in rent, and it was proven that monthly income was understated by more than $10,000 in prior years. Neal v. Hibbard, 296 Ga. 882, 770 S.E.2d 600 (2015).

- Without some evidence of the amount of regular, ongoing gift income to the father, attributing to him a monthly lump-sum gift income of $3,000 was not supported by the record. Dodson v. Walraven, 318 Ga. App. 586, 734 S.E.2d 428 (2012).

- Determination that there had been a substantial change in the husband's income was not an abuse of discretion as the husband was employed in the mortgage industry, which had been unstable, downsizing, and affected by the recession, and while the husband earned $48,000, rather than the $75,000 imputed to the husband at the time of the divorce, the trial court imputed income of $52,500 to the husband because the husband accepted a lower base salary in exchange for the chance of advancement. Strunk v. Strunk, 294 Ga. 280, 749 S.E.2d 701 (2013).

- In a child support case, the trial court properly included only $702 of the military father's $3,555 basic allowance for housing (BAH) in calculating the father's gross income because the difference was based on the father's deployment to Bahrain, and under O.C.G.A. § 19-6-15(f)(1)(E)(iv), BAH was to include only so much of the allowance that was not attributable to area variable housing costs. Wallace v. Wallace, 296 Ga. 307, 766 S.E.2d 452 (2014).

- When a mother sought to increase the father's child support under earlier provisions of O.C.G.A. § 19-6-19(a) based on his increased income, the trial court properly included capital gains realized by reselling real property in the father's gross income; earlier provisions of O.C.G.A. § 19-6-15 stated that gross income included "all other income" except for public assistance, and 26 U.S.C. § 61(a)(3) included "gains derived from dealings in property" in gross income. Sharpe v. Perkins, 284 Ga. App. 376, 644 S.E.2d 178 (2007), cert. denied, No. S07C1123, 2007 Ga. LEXIS 509 (Ga. 2007).

- In a divorce case when the wife was awarded child support, the trial court did not abuse the court's discretion in overruling the husband's objection to the wife's questions regarding checks that had been paid to him but that he had not deposited into his bank account. The wife was entitled to inquire whether the deposited and undeposited checks matched the amount of income reported by the husband. Leggette v. Leggette, 284 Ga. 432, 668 S.E.2d 251 (2008).

Trial court abused the court's discretion in calculating a father's gross income for purposes of a child support award because the court considered the gross revenue of a certain company, without accounting for business expenses and other deductions or the fact that the father only owned a one percent share of the company. Harrell v. Ga. Dep't of Human Res., 300 Ga. App. 497, 685 S.E.2d 441 (2009).

It is within judge's discretion to whom child support shall be paid. Mathews v. Mathews, 123 Ga. App. 81, 179 S.E.2d 547 (1970).

Trial court may properly order custodial parent to pay for support of minor children while visiting with the noncustodial parent. James v. James, 246 Ga. 233, 271 S.E.2d 151 (1980).

Trial court is not bound by an agreement between the parties regarding child support, nor is the court's obligation satisfied by simply adopting the agreement. The court is obligated to consider whether such support is sufficient based on the children's needs, and the parent's ability to pay. Arrington v. Arrington, 261 Ga. 547, 407 S.E.2d 758 (1991).

- Contractual agreement for modification providing for child support payments that exceed the statutory guidelines did not contravene O.C.G.A. § 19-6-15 or the public policy of the state. Kendrick v. Childers, 267 Ga. 98, 475 S.E.2d 604 (1996).

- Evidence supported the presence of special circumstances that provided sufficient justification for the court's reduction of the mother's child support obligation below the minimum percentage in the guidelines. Walker v. Walker, 248 Ga. App. 177, 546 S.E.2d 315 (2001).

- Even though under O.C.G.A. § 19-6-15(b)(5), the range of percentages of gross income to be considered for child support was 17 percent to 23 percent, the jury's award of periodic child support in the amount of approximately 40 percent of the father's gross income was proper and was affirmed because the jury found that this upward variation from the percentage table was justified by the fact that the mother had no income, and found that the father's ability to pay the amount ordered as permanent child support was shown by the fact that the father had been paying the same amount as temporary child support and alimony. Ward v. Ward, 268 Ga. App. 394, 601 S.E.2d 851 (2004).

Because the jury was presented with sufficient evidence via a husband's deposition and trial testimony supporting the jury's determination of the husband's monthly gross income, which included income from two landscaping businesses and a salary from the sheriff's department, which in turn supported a finding of special circumstances warranting an upward modification of child support, the husband was not entitled to a new trial. Dyals v. Dyals, 281 Ga. 894, 644 S.E.2d 138 (2007).

Superior court did not abuse the court's discretion when the court deviated from the child support guidelines in former O.C.G.A. § 19-6-15(b) based on the specific finding that special circumstances existed in that one spouse's gross income was approximately $90,000 per year while the other spouse had an income of only $325 per month, and the parties were sharing custody of their three children. Banciu v. Banciu, 282 Ga. 616, 652 S.E.2d 552 (2007).

- Based on the applicable version of the revised child support guidelines under O.C.G.A. § 19-6-15, the trial court properly exercised the court's discretion when the court imposed the presumptive amount of child support on a wife without applying a discretionary deviation under § 19-6-15(c)(2)(E) and (i)(1)(B); since no deviation was made, there was no requirement that an explanation be given of how that decision was reached. Rumley-Miawama v. Miawama, 284 Ga. 811, 671 S.E.2d 827 (2009).

Trial court's findings supporting the court's child support and alimony awards were proper because the trial court considered, inter alia, the husband's personal expenses paid by the husband's companies and the husband's loan application and financial affidavit in arriving at the court's determination of the husband's income; additionally, the trial court took into account the wife's status as a stay-at-home mother since the birth of the parties' son, the husband's conduct towards the wife, and the wife's potential income from the trial court's award to the wife of one of the husband's companies. The evidence also supported the trial court's finding that no deviation from the presumptive child support award was warranted under O.C.G.A. § 19-6-15(i) based on the alimony award. Walton v. Walton, 285 Ga. 706, 681 S.E.2d 165 (2009).

Trial court did not abuse the court's discretion in declining to make a deviation to the presumptive amount of child support because under O.C.G.A. § 19-6- 15(c)(2)(E)(iii) the trial court stated that the court did not find that the presumptive amount of child support was excessive or inadequate, or that it was unjust or inappropriate under the circumstances and also did not find that a downward deviation in the husband's support amount would be in the child's best interests; in order to grant any deviation, the trial court must find that the application of the presumptive amount of child support would be unjust or inappropriate and that the best interest of the child for whom support is being determined will be served by deviation from the presumptive amount of child support under § 19-6- 15(c)(2)(E)(iii). Willis v. Willis, 288 Ga. 577, 707 S.E.2d 344 (2010).

In a mother's paternity suit to establish the legitimation, custody, and support of her minor child by the father who worked as an NFL football player, the trial court did not err in failing to allow for a high income deviation under O.C.G.A. § 19-6- 15(i)(2)(A). The trial court considered the fact that the combined adjusted income of the parents exceeded $30,000 per month by $1,261.50, but exercised the court's discretion not to provide for a high income deviation. Jackson v. Irvin, 316 Ga. App. 560, 730 S.E.2d 48 (2012).

For purposes of the child support award, the juvenile court did not abuse the court's discretion in refusing to award the mother a deviation for the mother's visitation-related travel expenses because, although the parties had previously agreed to a deviation for travel expenses, which was incorporated into an earlier child support order, the juvenile court was not bound by the earlier consent order; and, furthermore, the mother's failure to cite in the mother's appellate brief to any legal authority supporting the mother's position was fatal to that claim of error. Noble v. Noble, 345 Ga. App. 799, 815 S.E.2d 150 (2018).

Large deviation from the child support guidelines could not stand insofar as the deviation was premised, in part, on an attempt to compensate the child for foregone support. Cousin v. Tubbs, 353 Ga. App. 873, 840 S.E.2d 85 (2020).

Trial court did not abuse the court's discretion in declining to make a deviation to the presumptive amount of child support based on parenting time since the parties were awarded joint physical custody. Calloway-Spencer v. Spencer, 355 Ga. App. 743, 845 S.E.2d 715 (2020).

- Trial court did not abuse the court's discretion by declining to consider the cost of the life insurance in calculating the parent's child support obligation because the evidence indicated that a parent's company, rather than the parent, paid the premiums on the parent's life insurance policies. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).

- Trial court erred by incorrectly starting with the father's presumptive amount of child support and incorrectly applying a parenting time deviation available only to the noncustodial parent under O.C.G.A. § 19-6-15(b)(1)-(7) when the court ordered the father to pay the noncustodial mother child support per month. Williamson v. Williamson, 293 Ga. 721, 748 S.E.2d 679 (2013).

- Former spouse's gross income was incorrectly calculated under O.C.G.A. § 19-6- 15(f)(2)(A) for the purposes of determining the spouse's child support obligation because the spouse's gross income included monthly child support received for a child from a previous marriage. Hammond v. Hammond, 282 Ga. 456, 651 S.E.2d 95 (2007).

- When that part of the verdict which made an allowance for the support of the defendant's minor children has the approval of the trial judge, the Supreme Court has no right to disturb it on the ground of excessiveness when its reasonableness as to the amount awarded has some support in the evidence. Hubbard v. Hubbard, 214 Ga. 294, 104 S.E.2d 451 (1958).

It is presumed that judgment for child support is based on sufficient evidence. Nichols v. Nichols, 209 Ga. 811, 76 S.E.2d 400 (1953).

- When the petition for divorce and alimony lists the names and ages of the minor children, and the verdict and decree awarding alimony states definitely how much alimony is to be paid each month for each child until the child attained the age of 18 years, it is not necessary that the verdict and decree should restate the names and ages of the children; and certainly such objection to the verdict and decree cannot be raised for the first time in defense of a proceeding for contempt of court for failure to pay the alimony decreed. Kirby v. Johnson, 188 Ga. 49, 2 S.E.2d 640 (1939).

When award is to group as family unit, Supreme Court could not attempt to separate amounts awarded to the mother from the amounts awarded to the children. Blalock v. Blalock, 214 Ga. 586, 105 S.E.2d 721 (1958).

Consent judgments have been uniformly recognized in this state, and have been given the same force and effect as judgments rendered in due course of litigation upon findings by a jury. Estes v. Estes, 192 Ga. 94, 14 S.E.2d 681 (1941).

- Trial courts, in determining whether to incorporate a marital settlement agreement into a final verdict or divorce decree, are required to make specific written findings as to the gross income of the husband and the wife, and the presence or absence of special circumstances justifying a departure from the percentages set out in the child support guidelines; however, a parties' marital settlement agreement called for the wife not to pay child support, and, instead, have her receive a lesser amount of alimony in lieu of paying child support as the right to child support belonged to the child and could not be waived by agreement of the parents. Swanson v. Swanson, 276 Ga. 566, 580 S.E.2d 526 (2003).

- Pursuant to O.C.G.A. § 19-6-15(f)(3)(A), a noncustodial parent was entitled to a credit against that parent's child support obligation for social security retirement benefits which became payable to the parent's dependent children following the execution of a settlement agreement as the parent earned the benefits and the agreement did not evidence a contrary intent; thus, the trial court erred in finding otherwise. Scarborough v. Scarborough, 282 Ga. 427, 651 S.E.2d 42 (2007).

Parents cannot by subsequent voluntary settlement nullify or modify final decree so as to deprive the child of the support to which the child is entitled by the verdict and decree. Glaze v. Strength, 186 Ga. 613, 198 S.E. 721 (1938); Hardy v. Pennington, 187 Ga. 523, 1 S.E.2d 667 (1939); Corriher v. McElroy, 209 Ga. 885, 76 S.E.2d 782 (1953).

- Guideline percentage is to be computed on the basis of the number of children for whom support is being determined in a particular case and, after that calculation is made, the final award can be adjusted on the basis of other children to whom the obligor owes support. Ehlers v. Ehlers, 264 Ga. 668, 449 S.E.2d 840 (1994); Hoodenpyl v. Reason, 268 Ga. 10, 485 S.E.2d 750 (1997).

Husband was entitled to a credit as a result of a child born to the husband and the husband's new wife. Strunk v. Strunk, 294 Ga. 280, 749 S.E.2d 701 (2013).

Social security disability payments received for benefit of children should be credited toward the father's obligation under an alimony decree. Perteet v. Summer, 246 Ga. 182, 269 S.E.2d 453 (1980).

- Because a lump settlement of a workers' compensation claim is primarily for future lost wages, it is within the scope of gross income and should be considered in calculating the child support obligation. Cromer v. Denmark, 273 Ga. 290, 540 S.E.2d 183 (2001).

Husband failed to establish that a trial court abused the court's discretion in awarding child support to his wife because in the court's order and attached schedules, the trial court made all of the specific written findings required by O.C.G.A. § 19-6-15, and the final decree gave the husband substantial, unsupervised visitation with his child, which was inconsistent with the husband's claims of a disability so severe as to render him utterly incapable of part-time employment. Larizza v. Larizza, 286 Ga. 461, 689 S.E.2d 306 (2010).

Trust fund established in decree is to be paid during a child's minority. Use contemplated which clearly extends beyond the age of 18 is an attempt to circumvent the statutory limitations on the duty to support and is void and unenforceable. Coleman v. Coleman, 240 Ga. 417, 240 S.E.2d 870 (1977).

Award of alimony to child of full amount of husband's earning capacity is excessive. Johnson v. Johnson, 131 Ga. 606, 62 S.E. 1044 (1908).

Trial court's award excessive based on exaggerated determination of spouse's earning capacity. Duncan v. Duncan, 262 Ga. 872, 426 S.E.2d 857 (1993).

Husband's responsibility for support did not extend to awarding title to property. He was not required to settle an estate upon his children. Clark v. Clark, 228 Ga. 838, 188 S.E.2d 487 (1972).

- O.C.G.A. § 19-6-15(h)(3) did not entitle a former spouse to collect an alleged debt for health care and extracurricular activity expenses of the parties' children through garnishment of the other spouse's wages without first reducing the alleged debt to a judgment. The amounts allegedly due for these expenses could not be computed from the terms of the divorce decree but required reference to evidence of specific expenditures and reimbursements. Stoker v. Severin, 292 Ga. App. 870, 665 S.E.2d 913 (2008).

- Agreement whereby one parent was obliged to pay to the other a fixed sum per month for the maintenance and support of minor children, continuing each month thereafter until the children reach majority, or die, or marry before the age, provides for a lump sum payment rather than an allocation for each child which would be reduced as each child became emancipated. Martin v. Martin, 254 Ga. 376, 329 S.E.2d 503 (1985).

- Provision in both the jury verdict and the final judgment requiring the husband to provide a home for his children is in the nature of child support. Scherberger v. Scherberger, 260 Ga. 635, 398 S.E.2d 363 (1990).

- Trial court properly excluded a husband's fringe benefits, including the husband's employer's contributions for life insurance, medical insurance, and a retirement plan, in calculating the husband's gross income for the purpose of determining a child support obligation because the benefits were not part of the husband's gross income for income tax purposes, and were not for daily personal living expenses; the decision was consistent with the 2005 amendment to O.C.G.A. § 19-6-15, which has a delayed effective date of July 1, 2006. Hayes v. Hayes, 279 Ga. 741, 620 S.E.2d 806 (2005).

- Trial court did not improperly include in a husband's gross income a company's payment on the loan for the husband's company-owned truck, the company's coverage of vehicle expenses, including gas, tags, insurance and repairs, the company's payment for the husband's cell phone, and the husband's use of a company-issued credit card because those benefits were properly considered fringe benefits and included in gross income under O.C.G.A. § 19-6-15(f)(1)(C) because those payments significantly reduced personal living expenses. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).

- Trial court erred in including the cost of housing in the husband's gross income because there was no evidence that the use of the house, owned by the husband's parents, was granted in the course of employment and, thus, it was not a fringe benefit. Scott v. Scott, 297 Ga. 775, 778 S.E.2d 230 (2015).

- Trial court properly included the cost of the husband's cellular telephone as a fringe benefit as the business paid for the phone and it significantly reduced the husband's personal expenses. Scott v. Scott, 297 Ga. 775, 778 S.E.2d 230 (2015).

- There was no error in the trial court's inclusion of the amount of the truck payment and expenses other than fuel in the husband's gross income for purposes of determining child support as the husband was permitted to drive the truck, paid for by the husband's parents' farming business, for personal use. Scott v. Scott, 297 Ga. 775, 778 S.E.2d 230 (2015).

- In calculating child support under earlier requirements of O.C.G.A. § 19-6-15, the trial court erred in including as part of the husband's gross income sums he had received from his employer as reimbursement for job-related moving expenses; reimbursement for moving expenses did not improve an obligor's financial position but merely maintained the status quo by offsetting the unusual and often significant costs incurred as part of a job-related move. Padilla v. Padilla, 282 Ga. 273, 646 S.E.2d 672 (2007).

- Trial court erred in failing to include the book royalties a husband received in calculating the husband's gross income for the purpose of determining a child support obligation because O.C.G.A. § 19-6-15(b)(2) required that the trial court include compensation for personal services and all other income when calculating a party's obligation for child support. Hayes v. Hayes, 279 Ga. 741, 620 S.E.2d 806 (2005).

- Trial court did not erroneously count a husband's income twice by awarding portions of his business in the child support awards and again in the property division as "business alimony". Under both capitalization methods, the wife's expert deducted a reasonable salary expense for the husband. With the separate bases for the alimony award and the property division clearly acknowledged before the court, there was no double dipping. Miller v. Miller, 288 Ga. 274, 705 S.E.2d 839 (2010).

- O.C.G.A. § 19-6-15(b)(1) and (2) do not address economic in-kind benefits and thus do not require the inclusion of such benefits in gross income; O.C.G.A. § 19-6-15(b)(4), however, does specifically address such benefits and provides only that those benefits may be included in calculating the obligor's gross monthly income. Hayes v. Hayes, 279 Ga. 741, 620 S.E.2d 806 (2005).

- Trial court erred in adjusting the parent's gross income for a preexisting child support order under O.C.G.A. § 19-6-15(f)(5)(B) as no such order satisfying the time qualifications of the statute existed. Heintz v. Heintz, 301 Ga. 209, 800 S.E.2d 293 (2017).

- Trial court properly deviated from the child support guidelines under O.C.G.A. § 19-6-15(c) based on the court's finding that the husband earned an average of $1 million per year during the marriage and continued to have the potential to earn this sum; the trial court took into account the income and earning potential of both spouses as well as the historical needs of the children. Bloomfield v. Bloomfield, 282 Ga. 108, 646 S.E.2d 207 (2007).

Trial court erred in denying a wife's motion for a new trial, which argued that a divorce decree contained a deviation from the child support guidelines without including any findings stating why the deviation was appropriate because the separation agreement between the wife and her husband, as well as the trial court's order incorporating that agreement, contained a deviation since there was, at least, an $18 difference in the amount of child support mandated by the child support guidelines and that which was actually being paid by the parties, and the trial court's order contained none of the findings required by O.C.G.A. § 19-6-15; because the parties' separation agreement did not comply with the provisions contained in § 19-6-15 and did not contain findings of fact as required to support a deviation, the trial court should have rejected the agreement. Holloway v. Holloway, 288 Ga. 147, 702 S.E.2d 132 (2010).

In determining a father's child support obligation, the trial court erred in applying a nonspecific deviation from the presumptive amount of child support to account for his support obligations to another child because the current version of O.C.G.A. § 19-6-15 does not contemplate a specific variance of a child support award based on a party's support obligations to another household. The record failed to show that the father was paying any support for the subsequent child, and his ability to pay all of his child support obligations was a matter of speculation. Jackson v. Irvin, 316 Ga. App. 560, 730 S.E.2d 48 (2012).

- Trial court abused the court's discretion by ordering a deviation for life insurance premiums because the court failed to justify the deviation by setting forth the court's findings; thus, a remand was required on that issue. Black v. Black, 292 Ga. 691, 740 S.E.2d 613 (2013).

Deviation for visitation-related travel expenses was not an abuse of discretion on the part of the trial court because the mother had the option to remain with the children in the marital home for which the father was financially responsible, but chose instead to move to New York and incur unnecessary expenses. Black v. Black, 292 Ga. 691, 740 S.E.2d 613 (2013).

- Trial court erred in applying a deviation from the presumptive amount of child support for extraordinary educational expenses without complying with O.C.G.A. § 19-6-15(c)(2)(E) as the trial court did not make any findings as to what the presumptive amount would have been or why an application of the guideline would have been unjust or inappropriate. Heintz v. Heintz, 301 Ga. 209, 800 S.E.2d 293 (2017).

- Trial court did not abuse the court's broad discretion in setting the amount of a child support award because nothing in the child support guidelines statute, O.C.G.A. § 19-6-15, mandated that the trial court calculate a discounted present value, and a husband did not propose or provide supporting evidence of a discount rate that better reflected the economic outlook; the trial court recognized the court's discretion to engage in a present value calculation but declined to do so, explaining that the husband failed to show that such a reduction would be appropriate in light of the current economic climate, one in which even the most secure financial investments offer extremely low rates of return. Mullin v. Roy, 287 Ga. 810, 700 S.E.2d 370 (2010).

- Trial court properly set child support at 30 percent of the husband's earnings as under earlier provisions of O.C.G.A. § 19-6-15(b)(5) the applicable percentage range was 25 to 32 percent, and the trial court clearly applied a correct percentage; the court was not required to reduce the award of child support due to health insurance premiums or to eliminate the insurance requirement. Messaadi v. Messaadi, 282 Ga. 126, 646 S.E.2d 230 (2007).

Trial court erred by ordering a parent to maintain health insurance on the parent's minor child because the court failed to account for the parent's payment of health insurance in calculating the parent's child support obligation. Dupree v. Dupree, 287 Ga. 319, 695 S.E.2d 628 (2010).

Gross income does not include employee benefits that are typically added to the salary, wage, or other compensation that a parent may receive as a standard added benefit including, but not limited to, employer paid portions of health insurance premiums. Hendry v. Hendry, 292 Ga. 1, 734 S.E.2d 46 (2012).

Husband was properly awarded a credit for the cost of providing health insurance for the children. Strunk v. Strunk, 294 Ga. 280, 749 S.E.2d 701 (2013).

- Findings that a husband's income was $65,000 per year for the purposes of calculating child support were not clearly erroneous as evidence was presented that the husband often would not take business engagements unless the husband could make at least $10,000 and the husband testified that the husband's gross earnings varied from $67,000 to $88,000 per year. Vereen v. Vereen, 284 Ga. 755, 670 S.E.2d 402 (2008).

Trial court did not abuse the court's discretion in the court's review of a husband's history of Internal Revenue Service Schedule K-1 income because other amounts not actually received, e.g., payroll taxes, were included in gross income under O.C.G.A. § 19-6-15(f)(1)(A); the statutory guidelines provide only that income from a closely held corporation "should be carefully reviewed" when determining an appropriate level of gross income to use in calculating child support pursuant to § 19-6-15(f)(1)(B). Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).

- Because the trial court properly found that the monthly net business profit listed on a husband's child support worksheet was the most credible calculation of his monthly income, and because a child's competitive cheerleading expenses were not a "necessity," the trial court properly awarded child support to the wife pursuant to O.C.G.A. § 19-6-15(f)(1)(B) and (i)(2)(J)(ii). Ellis v. Ellis, 290 Ga. 616, 724 S.E.2d 384 (2012).

- Superior court erred in attempting to recast the court's dismissal of a husband's first petition for modification of child support as "simply a sanction" and not an adjudication on the merits so as to render the dismissal outside the ambit of O.C.G.A. § 19-6-15(k)(2) because in dismissing the husband's first petition for modification, the superior court did not specify that the order was not an adjudication on the merits, and under O.C.G.A. § 9-11-41(b), it was a final order on the claim for downward modification of child support. Bagwell v. Bagwell, 290 Ga. 378, 721 S.E.2d 847 (2012).

- Mother was entitled to reversal of the trial court's order awarding no child support because the child support worksheets contained erroneous facts and the nonspecific deviations were erroneous; inaccurate factual data was plugged into the worksheets for the purpose of arriving at a pre-determined result that the trial judge announced at the hearing, to "zero out" any child obligations of the parties to each other. Parker v. Parker, 293 Ga. 300, 745 S.E.2d 605 (2013).

Trial court's award of child support was vacated because the trial court's order referenced two child support worksheets purportedly attached as Exhibits, but the worksheets were not attached to the final order; the worksheets and schedules corresponding with the trial court's order were later filed, apparently by the mother's counsel, but were not incorporated into the trial court's order, and it was unclear if the trial court even had the worksheets and schedules in the court's possession when the final order was entered; and pertinent information that would otherwise be found on the worksheets and Schedule E, including that pertaining to deviations and special circumstances, was not included within the order itself. Moore v. Moore, 346 Ga. App. 58, 815 S.E.2d 242 (2018).

- Trial court did not abuse the court's discretion by finding that a father was in contempt for the failure to meet a support obligation because, under the decree, the father was to pay $2,000 per month in child support and after December 15, 2010, following an involuntary job termination, the father was to pay $1,040 per month, but did not do so, paying only $179 per month, or $1,821 less than the original figure. Friday v. Friday, 294 Ga. 687, 755 S.E.2d 707 (2014).

- On appeal from a child support and visitation order, because a parent failed to support claims of error regarding the order, including the trial court's application of the revised child support guidelines under O.C.G.A. § 19-6-15 et seq., with any citation of authority or argument, and failed to provide the appeals court with a transcript of the proceedings below, that parent's claims were rejected and the orders entered by the trial court had to be affirmed. Sebby v. Costo, 290 Ga. App. 61, 658 S.E.2d 830 (2008).

- Since a parent's children were found to be deprived and were placed temporarily with relatives, pursuant to O.C.G.A. § 15-11- 28(c)(2)(A), the trial court had jurisdiction to order the parent to pay temporary support. However, the court lacked jurisdiction to enter a final award of support under O.C.G.A. § 19-6-15 as no final order was entered disposing of the case. In the Interest of R.F., 295 Ga. App. 739, 673 S.E.2d 108 (2009).

- Trial court erred in failing to hold a hearing as required by Ga. Unif. Super. Ct. R. 6.3 on a husband's post-trial motion for a new trial on the basis of the trial court's failure to make child support findings as required by O.C.G.A. § 19-6-15. The husband was not required to file a written request for oral argument. Kuriatnyk v. Kuriatnyk, 286 Ga. 589, 690 S.E.2d 397 (2010).

- In a child support modification action that resulted in an increase in the father's child support, even if not to the extent requested by the mother, the mother was the prevailing party under O.C.G.A. § 19-6-15(k)(5), and only the mother could be awarded attorney's fees; the trial court erred in finding that there could be, and were, two prevailing parties. Mironov v. Mironov, 296 Ga. 114, 765 S.E.2d 326 (2014).

Cited in Jackson v. Jackson, 179 Ga. 152, 175 S.E. 456 (1934); Rozetta v. Banks, 183 Ga. 701, 189 S.E. 513 (1937); Glaze v. Strength, 186 Ga. 613, 198 S.E.2d 721 (1938); Murphey v. Murphey, 215 Ga. 19, 108 S.E.2d 872 (1959); Kennison v. Lee, 217 Ga. 155, 121 S.E.2d 821 (1961); Levine v. Seley, 217 Ga. 384, 123 S.E.2d 1 (1961); Kendrick v. Kendrick, 218 Ga. 284, 127 S.E.2d 379 (1962); DuPree v. DuPree, 224 Ga. 52, 159 S.E.2d 708 (1968); Mullinax v. Mullinax, 234 Ga. 553, 216 S.E.2d 802 (1975); Anderson v. Anderson, 237 Ga. 886, 230 S.E.2d 272 (1976); Ford v. Ford, 243 Ga. 763, 256 S.E.2d 446 (1979); Kirkpatrick v. Woodruff, 243 Ga. 736, 256 S.E.2d 465 (1979); Dupre v. Scappaticcio, 244 Ga. 179, 259 S.E.2d 440 (1979); Stewart v. Stewart, 160 Ga. App. 463, 287 S.E.2d 378 (1981); Green v. Krebs, 245 Ga. App. 756, 538 S.E.2d 832 (2000); Frazier v. Frazier, 280 Ga. 687, 631 S.E.2d 666 (2006); Penny v. McBride, 282 Ga. App. 590, 639 S.E.2d 561 (2006); McCoy v. McCoy, 281 Ga. 604, 642 S.E.2d 18 (2007); Bankston v. Warbington, Ga. App. , S.E.2d (Mar. 24, 2015); Wilson v. Guerrero, 353 Ga. App. 501, 838 S.E.2d 588 (2020); Spirnak v. Meadows, Ga. App. , 844 S.E.2d 482 (2020).

It is duty of jury to fix amount minor children shall be entitled to for their permanent support. Hardy v. Pennington, 187 Ga. 523, 1 S.E.2d 667 (1939).

Jury is vested with discretion as to amount, character, and duration of permanent support to be awarded to the child or children of the unsuccessful marriage, and an instruction, that if the jury found in favor of the children, the jury should fix an allowance that would be sufficient to provide for their maintenance, protection, and education until their majority is erroneous. Mell v. Mell, 190 Ga. 508, 9 S.E.2d 756 (1940).

- In determining husband's gross income, the jury was not entitled to "discount" amounts such as retirement pay awarded to the wife, the minor child's college costs, insurance premiums and other factors. Franz v. Franz, 268 Ga. 465, 490 S.E.2d 377 (1997).

- On the husband's ability to pay, the jury may take into consideration his age, the condition of his health, his material resources, his present income, and any previous allowance voluntarily made by the husband for the support of the wife. Fried v. Fried, 211 Ga. 149, 84 S.E.2d 576 (1954) (decided prior to the 1989 amendment establishing guidelines for child support awards).

Settlement between husband and wife, in which no provision is made for child, is not considered by jury in estimating the allowance to a child which had not been previously awarded the child by decree of the court. Johnson v. Johnson, 131 Ga. 606, 62 S.E. 1044 (1908).

- Jury award which based child support solely on a percentage computation of the father's income, without setting a flat sum for which he was liable, did not comply with the requirement of the statute that a definite amount be specified. Newsome v. Newsome, 237 Ga. 221, 227 S.E.2d 347 (1976); Wilcox v. Wilcox, 242 Ga. 598, 250 S.E.2d 465 (1978).

- When viewed in connection with the remedy provided in former Code 1933, § 30-207 (see now O.C.G.A. § 19-6-15), the principle of former Code 1933, § 74-105 (see now O.C.G.A. § 19-7-2) operates to authorize, though it does not require, the jury to find a support for the minor children until their majority. Mell v. Mell, 190 Ga. 508, 9 S.E.2d 756 (1940).

Amount found by jury may or may not be calculated to support children until majority. Mell v. Mell, 190 Ga. 508, 9 S.E.2d 756 (1940).

Modification of Award

Enforceability of agreement between parties.

- While parties may enter into an agreement concerning modification of child support, the agreement becomes an enforceable agreement only when made an order of the court pursuant to O.C.G.A. § 19-6-19. Pearson v. Pearson, 265 Ga. 100, 454 S.E.2d 124 (1995).

Although a trial court was authorized to conclude that the parents had agreed to submit the parties' settlement agreement to the court, the court was not authorized to enforce the terms of the agreement as to the past-due arrearage, or to modify future child support payments without ensuring that such a modification was in the best interests of the child. Wright v. Burch, 331 Ga. App. 839, 771 S.E.2d 490 (2015).

- When the original child support decree provided for a reduction of child support upon the oldest child's majority, thus providing an ending time for that portion of the parent's support obligation relating to the oldest child, the trial court in a modification action had no authority to extend the period for which the parent would be required to pay child support for three children. Eubanks v. Rabon, 281 Ga. 708, 642 S.E.2d 652 (2007).

- Guidelines added by the 1989 amendment may be applied retroactively to a petition to modify child support provisions in a decree entered before the effective date of the amendment. Walker v. Walker, 260 Ga. 442, 396 S.E.2d 235 (1990).

Child support guidelines of O.C.G.A. § 19-6-15 apply to child support modification actions and to divorce actions seeking to establish an initial obligation of child support. That section can be applied retroactively to modify a 1983 divorce judgment. Riggs v. Darsey, 260 Ga. 487, 396 S.E.2d 905 (1990).

Child-support guidelines are applicable to a modification action (Riggs v. Darsey, 260 Ga. 487, 396 S.E.2d 905 (1990)), and the trial court must review the agreement in light of the child support amounts contained in the child-support guidelines. Pearson v. Pearson, 265 Ga. 100, 454 S.E.2d 124 (1995).

- Trial court did not err in imputing income of $2,500 to an unemployed parent based on the parent's training and experience as a paralegal and the trial court's finding that the parent had failed to show efforts to obtain employment and was choosing not to work. The downward adjustment by the trial court was not retroactive to the date of the petition for modification; O.C.G.A. § 19-6-15(j) did not apply to this case, in which only modification of child support was sought. Galvin v. Galvin, 288 Ga. 125, 702 S.E.2d 155 (2010).

- Parent's petition for downward modification of the parent's child support obligation should have been dismissed because the parent did not invoke the exception contained in O.C.G.A. § 19-6-15(k)(2)(C) in the parent's successive petition; the relevant time frame for the parent's alleged loss of income in excess of the statutory exception was from the date of the prior modification ruling, and the material allegations of the petition were essentially that of the prior petition for modification. Bagwell v. Bagwell, 290 Ga. 378, 721 S.E.2d 847 (2012).

- Trier of fact may place a time limit on child support but only if the court ties it to some financial consideration. Scherberger v. Scherberger, 260 Ga. 635, 398 S.E.2d 363 (1990).

Award of a home to the wife and the children until the youngest child turns 18 or the wife remarries constitute an illegal future modification of child support not tied to income fluctuation. Scherberger v. Scherberger, 260 Ga. 635, 398 S.E.2d 363 (1990).

- When the Department of Human Resources (DHR) petitions the superior court to adopt the Department's recommendation, the court is not required to find a need for additional support but, without regard to whether a child is receiving public assistance, may increase child support based solely on a significant inconsistency between an existing order and the amount which would result from application of the child support guidelines; the Child Support Recovery Act, O.C.G.A. § 19-11-1 et seq., does not contain any basis for continuing to distinguish between the procedure available since the child is receiving public assistance and that which is available in the absence of any such assistance. The trial court erred in concluding that evidence of the need for additional support was necessary and that DHR lacked standing, and in failing to apply child support guidelines and to justify any departure therefrom. Falkenberry v. Taylor, 278 Ga. 842, 607 S.E.2d 567 (2005).

In a child support modification action, the trial court erred in concluding that evidence of the need for additional support was necessary and that the Department of Human Resources (DHR) lacked standing to file a modification action on behalf of a child not receiving public assistance unless the court could show the child's need for additional support, and in failing to apply the child support guidelines of O.C.G.A. § 19-6-15 and to justify any departure therefrom; by express statutory amendment, the General Assembly no longer reserved for the private bar those modification actions which involved children who did not receive public assistance and needed no additional support, but whose court-ordered provider enjoyed an enhanced financial status. Falkenberry v. Taylor, 278 Ga. 842, 607 S.E.2d 567 (2005)(Unpublished).

Trial court erred by requiring that an ex-wife refrain from applying for any government assistance for the children while the ex-wife receives child support from the ex-husband because it was an effort to make a predetermined finding with respect to a potential future modification and was unauthorized under O.C.G.A. § 19-6-15. Singh v. Hammond, 292 Ga. 579, 740 S.E.2d 126 (2013).

- Trial court's order modifying child support outside the range of the Georgia Child Support Guidelines was required to state the amount of support that would have been required under the guidelines and to contain a written finding as to the father's gross income. Faulkner v. Frampton, 216 Ga. App. 785, 456 S.E.2d 88 (1995).

Order that the father pay increased child support based on a substantial change in the father's financial condition was reversed because although the jury checked several special circumstances listed on the verdict form, the jury failed to explicitly state whether an award under the guidelines was excessive; the special circumstances checked did not imply that the jury thought the award was excessive, in fact, the checked circumstances supported an inference that the guideline award was inadequate and that the jury intended for the father to pay more, not less. Lewis v. Scruggs, 261 Ga. App. 573, 583 S.E.2d 240 (2003).

- Wife was entitled to an upward modification of child support because the wife presented evidence that the husband's gross monthly income had increased from $8,898 to $10,700.91 during the period between entry of the final divorce decree and the filing of the petition for modification and there was evidence that the husband's net worth had increased by almost three million dollars. That evidence supported the trial court's finding of a substantial change in income and financial status sufficient to authorize modification of the support award and supported the trial court's deviation from the presumptive amount of child support based on a parent's financial ability to provide for private school education. Odom v. Odom, 291 Ga. 811, 733 S.E.2d 741 (2012).

- While the trial court did not erroneously set a mother's child support obligation at a percentage well below the guidelines, the court lacked the authority to completely forgive the mother's arrearage as the General Assembly did not intend to permit forgiveness of past-due child support arrearage, regardless of whether the modification proceeding fell under the general statutory scheme or the Child Support Recovery Act, O.C.G.A. § 19-11-1 et seq. Ga. Dep't of Human Res. v. Prater, 278 Ga. App. 900, 630 S.E.2d 145 (2006).

In modifying a father's child support obligation, the trial court erred in increasing support above the amount in the guidelines without making a finding of special circumstances warranting such a deviation; furthermore, the trial court erred in not applying the guidelines to the father's counterclaim for an increase of the support the mother was to pay the father during the summer. Eubanks v. Rabon, 281 Ga. 708, 642 S.E.2d 652 (2007).

Modification of a child support obligation in a garnishment action, rather than a petition to modify, was erroneous. Twineham v. Daniel, 223 Ga. App. 25, 476 S.E.2d 814 (1996).

- O.C.G.A. § 19-6- 15(h)(3)(B)(i) does not authorize garnishment for uninsured health care expenses that have not been reduced to a money judgment without compliance with the requirements of the more restrictive prejudgment garnishment procedure set out in O.C.G.A. § 18-4-40. Stoker v. Severin, 292 Ga. App. 870, 665 S.E.2d 913 (2008).

In a proceeding to legitimate a child, the trial court did not err in calculating the petitioning parent's child support obligation to be $2,200 per month as the trial court relied on the testimony of the petitioning parent's accountant, the ex-spouse who remained a business partner, and the petitioning parent's tax returns and self-employment income documentation. Appling v. Tatum, 295 Ga. App. 78, 670 S.E.2d 795 (2008).

- In increasing a remarried father's child support obligation based on increased income, the trial court properly considered his support obligation to his child by his new wife; the trial court had considered the father's income as well as his current wife's income and ultimately decided that based on his obligations to his current household, the father was entitled to reduce the upward modification of child support payments. Sharpe v. Perkins, 284 Ga. App. 376, 644 S.E.2d 178 (2007), cert. denied, No. S07C1123, 2007 Ga. LEXIS 509 (Ga. 2007).

- Following a change of custody from mother to father, it was error to include child support formerly paid by the father in the mother's income for purposes of calculating her child support obligation. Martin v. Greco, 225 Ga. App. 752, 484 S.E.2d 789 (1997).

- Since the parties' settlement agreement modified custody so each would be the residential custodian of one child, the trial court erred by approving a provision in the agreement that neither would pay the other child support because the court did not determine whether this provision complied with the child support guidelines. Ford v. Hanna, 293 Ga. App. 863, 668 S.E.2d 271 (2008).

Trial court did not address whether there had been a change in the financial circumstances of the husband since the original child support award. If the husband's financial status had not substantially changed, then no modification was appropriate, if modification was appropriate, then the court was required to use the child support guidelines to calculate the new amount. Wetherington v. Wetherington, 291 Ga. 722, 732 S.E.2d 433 (2012).

Trial court's child support award was reversed and the case was remanded for reconsideration because the trial court's award of child support was predicated on the court's decision to change custody of the parties' son, which change was vacated. Blue v. Hemmans, 327 Ga. App. 353, 759 S.E.2d 72 (2014).

Temporary child support judgment was reversed and the case remanded for entry of an order that complied with O.C.G.A. § 19-6-15(f)(4)(D) because the order showed on the order's face that the guidelines were not used and that the trial court was unable to calculate various items relating to child support and arrears; if modification was appropriate, then the trial court was required to use the child support guidelines to calculate the new amount. Neal v. Hibbard, 296 Ga. 882, 770 S.E.2d 600 (2015).

Trial court did not err in including the $1400 per month in work-related expenses from the original child support calculation as determined at the time of divorce because the trial court found, and the father does not dispute, that neither party demonstrated that there had been any change in the monthly work-related child care expenses nor did either party allege a change in the needs of the children; thus, the modification was based solely on the increase in the father's income. Steed v. Steed, Ga. App. , 843 S.E.2d 21 (2020).

- Trial court's apportionment of the costs of the children's extracurricular activities on a pro rata basis was in error because the costs of extracurricular activities were included in the presumptive amount of child support and a deviation from that amount required the trial court to follow Georgia's statutory child support guidelines and justify the deviation with written findings of fact; thus, a remand was required on that issue. Park-Poaps v. Poaps, 351 Ga. App. 856, 833 S.E.2d 554 (2019).

- In a father's cross-appeal, the trial court erred by ruling that the mother could deduct the future costs of plane tickets that she purchased for the children to visit her, not to exceed five trips per year, because the travel deviation granted failed to include any cost information and, therefore, was too speculative to fall within the parameters of the child support guidelines. Park-Poaps v. Poaps, 351 Ga. App. 856, 833 S.E.2d 554 (2019).

- Child support award made in the final order was reversed because the trial court did not address whether there had been a change in the financial circumstances of the father or the needs of the child since the 2013 order denying any child support, but instead the trial court summarily denied the father's request to pay child support as the court found that it was still not in the child's best interests to have contact with the father. Selvage v. Franklin, 350 Ga. App. 353, 829 S.E.2d 402 (2019).

- In the mother's petition to modify child support, there was no articulated basis for application of a specified discretionary deviation from the presumptive child support obligation because the history of the parties was not a ground for deviation in child support, and the modified physical custody awarded the father fell far short of being substantially equal to that with the mother. Crook v. Crook, 293 Ga. 867, 750 S.E.2d 334 (2013).

- Trial court erred by abating a portion of the father's child support obligation for the period that the child was residing with the father and concluding that allowing an abatement during a time of deployment would not do injustice to the mother because the award of the trial court did not state how deviation was in the best interest of child, which required a remand for those necessary findings. Dingle v. Carter, 350 Ga. App. 255, 829 S.E.2d 604 (2019).

- A 15-month delay in the effective date of an upward modification of child support was improper under O.C.G.A. § 19-6-15(k)(3)(B). When a modification award involved at least a 30% difference, as in the instant case, the new child support award could be phased in over a period of up to two years with at least an initial immediate adjustment of not less than 25 percent of the difference. Hampton v. Nesmith, 294 Ga. App. 514, 669 S.E.2d 489 (2008).

- Trial court could properly award child support to a parent who filed a petition for change of custody and child support, even though the child had reached the age of 18 by the time the petition was considered. The parent was not divested of the right to seek child support for the period of time between the filing of the petition and the date on which the child turned 18, and as the child had not yet completed high school, an order for support beyond the child's 18th birthday could be entered. Wade v. Corinthian, 283 Ga. 514, 661 S.E.2d 532 (2008).

- Trial court did not abuse the court's discretion by refusing to apply discretionary parenting-time deviation from the presumptive child support amount set forth in O.C.G.A. § 19-6-15(i)(2)(K) as sought by a parent because the parent failed to show a special circumstance showing the presumptive amount of support excessive or that the child's best interest would be served by subtracting from the presumptive amount. Hamlin v. Ramey, 291 Ga. App. 222, 661 S.E.2d 593 (2008).

- Parent did not prove entitlement to a modification of child support because, even assuming the money the parent received from a trust of which the parent and the children's grandparent were the sole beneficiaries was a gift, it had to be included in the parent's gross income under O.C.G.A. § 19-6-15(f)(1)(A)(xvii). In the Interest of R.F., 295 Ga. App. 739, 673 S.E.2d 108 (2009).

- Because the father consented to the modification of the father's monthly child support obligation, although the father disputed the amount that the father should be required to pay under the statutory guidelines, the father waived any objection to whether the threshold requirements for the child support modification were otherwise met, including a change in the father's financial status or a change in the needs of the child. Moore v. Moore, 346 Ga. App. 58, 815 S.E.2d 242 (2018).

- When a parent agreed to child support in excess of the O.C.G.A. § 19-6-15 support guidelines and did not subsequently show a reduction in the parent's financial status and income, a downward modification of child support under O.C.G.A. § 19-6-19(a) was properly denied. Moccia v. Moccia, 277 Ga. 571, 592 S.E.2d 664 (2004).

Because two years had not elapsed from a prior court order disposing of an earlier petition for support modification filed by one parent, the trial court did not err when the court dismissed under O.C.G.A. § 19-6-15(k)(2) the portion of a petition seeking modification of the child-support award. Avren v. Garten, 289 Ga. 186, 710 S.E.2d 130 (2011).

- Portion of the juvenile court's order modifying child support had to be reversed because the order did not reflect a finding by the juvenile court of a substantial change in either the parents' income, financial status, or the child's needs. Grailer v. Jones, 349 Ga. App. 625, 824 S.E.2d 118 (2019).

- Trial court properly designated a father as the custodial parent pursuant to O.C.G.A. § 19-6-15(a)(9), and required the mother to pay child support to the father because it was undisputed that the child was spending equal time with the parents and that the mother had the higher income. Stoddard v. Meyer, 291 Ga. 739, 732 S.E.2d 439 (2012).

Trial court did not err by imputing income to the mother because there was evidence that the mother and new husband had determined that it was to the advantage of their children that the mother not work outside the home. Carr-MacArthur v. Carr, 296 Ga. 30, 764 S.E.2d 840 (2014).

- Trial court record was devoid of evidence that a parent had the ability or means to earn an amount found by the trial court, such that the court's grant of the other parent's request for an upward modification of the parent's child support obligation could not stand; the evidence was uncontroverted that the parent's income and earning capacity had dramatically decreased. Herrin v. Herrin, 287 Ga. 427, 696 S.E.2d 626 (2010).

- Trial court abused the court's discretion in increasing a mother's child support obligation because the court failed to determine whether her income had substantially changed from the entry of the divorce decree pursuant to O.C.G.A. § 19-6-15(k)(4), and even if the trial court correctly disregarded the reduction in the mother's income, the evidence failed to show an increase in the mother's income since her divorce; while it appeared that the trial court modified the child support award consistent with existing child support guidelines, the court had no valid basis to do so. Harris v. Williams, 304 Ga. App. 390, 696 S.E.2d 131 (2010), overruled on other grounds, Viskup v. Viskup, 291 Ga. 103, 727 S.E.2d 97 (2012).

- Trial court did not abuse the court's discretion by increasing the mother's child support obligation based on the mother's increased income because the affidavits the mother submitted established that her gross monthly income increased from $5,917 to $8,673 per month, and the mother presented no evidence at the 2019 hearing that her financial status was different from her wage income. Park-Poaps v. Poaps, 351 Ga. App. 856, 833 S.E.2d 554 (2019).

- Trial court, by including an additional child support provision requiring a father to pay an annual payment of 25 percent of his gross commissions on top of the presumptive child support amount, circumvented the requirement that a court only may deviate from the presumptive amount after making the necessary findings in O.C.G.A. § 19-6-15(i)(1)(B). Stowell v. Huguenard, 288 Ga. 628, 706 S.E.2d 419 (2011).

- Child support award was reversed because nothing in O.C.G.A. § 19-6-15 authorized the trial court to consider the income or other resources of the father's new spouse as a part of the calculation of the child support obligation as his new wife had no legal obligation to contribute, directly or indirectly, to the support of the parties' three children. Blumenshine v. Hall, 329 Ga. App. 449, 765 S.E.2d 647 (2014).

- Trial court's finding that the father was engaging in voluntary underemployment was upheld because the trial court found that a downward modification of the amount of child support was not in the child's best interest, the father was unable to produce documentation to support his claims of income and that after his lay-off, he was working only part time, and the record showed that the father was able to afford to take vacations while falling behind in child support and visitation. Spirnak v. Meadows, Ga. App. , 844 S.E.2d 482 (2020).

- It was error for the trial court in modifying a child support award to take judicial notice of an increase in the needs of the children because the question of whether there had been such an increase would be a matter of proof if it had been placed in issue; the error was harmless, however, as the modification order did not expressly mention an increase in the children's needs as a basis for increasing the child support. Eubanks v. Rabon, 281 Ga. 708, 642 S.E.2d 652 (2007).

- Father's child support obligation did not continue to accrue at the same rate after the mother was served with the father's petition to modify child support. Under O.C.G.A. § 19-6-15(j), support due before the entry of a modification order did not accrue to the extent that the obligation was based on the father's income from employment from which the father had been involuntarily terminated. Morgan v. Bunzendahl, 316 Ga. App. 338, 729 S.E.2d 476 (2012).

- Since the modification order encompassed and modified the entire child support obligation including the duty to pay miscellaneous expenses, and the order modified child support without deviation for miscellaneous expenses, the order did not leave the prior miscellaneous expense provision in full force and effect and the father could not be in contempt for failure to pay those expenses. East v. Stephens, 292 Ga. 604, 740 S.E.2d 156 (2013).

- In a child custody modification proceeding, the trial court erred by awarding attorney fees to the father in the amount of $4,000 under O.C.G.A. § 19-9-3 as the award was not supported by the record since the trial court did not explain the statutory basis for the award and did not enter any findings necessary to support the award as required by O.C.G.A. § 19-6-15(k)(5). Kuehn v. Key, 325 Ga. App. 512, 754 S.E.2d 103 (2014).

In an action to modify child custody, the trial court was authorized to award attorney fees under O.C.G.A. §§ 19-6-15(k)(5) and19-9-3(g); however, because the mother and the trial court did not state a statutory basis for the award, the award was vacated and the case was remanded for the trial court to explain the statutory basis for the award and to enter any necessary factual findings. Hill v. Davis, 337 Ga. App. 683, 788 S.E.2d 570 (2016).

- Trial court erred in awarding attorney fees without specifying a statutory or factual basis for the award as there were two plausible statutory bases for the award, O.C.G.A. § 9-15-14 or O.C.G.A. § 19-6-15, and the record contained no statement regarding the amount attributable to the pursuit or defense of claims for which attorney fees were recoverable or how the trial court calculated the court's award, which was less than requested. Hall v. Hall, 335 Ga. App. 208, 780 S.E.2d 787 (2015).

- Order awarding a mother attorney fees was vacated and the matter remanded to the trial court as other than the mother's testimony as to the amount paid and still owed, there were no bills presented, no testimony from either of the mother's attorneys as to the reasonableness of their fees, and no breakdown to establish what services were provided by the attorneys. Steed v. Steed, Ga. App. , 843 S.E.2d 21 (2020).

- Award of attorney fees to a mother in a child custody and support proceeding was vacated because although in the modification order the trial court made references to factors that indicate that the award was being made under O.C.G.A. § 9-15-14(b) due to sanctionable conduct, the trial court also referred to the relative financial position of the parties, which would indicate the award was being made under O.C.G.A. § 19-6-2; thus, further proceedings on the issue of attorney fees was required. Wilson v. Guerrero, 353 Ga. App. 501, 838 S.E.2d 588 (2020).

Writing Requirement

Written findings required.

- Trial court, upon modifying an award of child support, must enter written findings of special circumstances in order to deviate, up or down, from the child support guidelines. Ehlers v. Ehlers, 264 Ga. 668, 449 S.E.2d 840 (1994).

Award of child support in the case sub judice being beyond the range of statutory guidelines, the trial court erred in failing to provide the required written findings. Kennedy v. Adams, 218 Ga. App. 120, 460 S.E.2d 540 (1995).

Even though O.C.G.A. § 19-6-15 was amended since the finding in Ehlers v. Ehlers, 264 Ga. 668, 449 S.E.2d 840 (1994), the requirement for written findings remains. Department of Human Resources v. Wilcox, 219 Ga. App. 757, 466 S.E.2d 662 (1996).

Trial court erred in setting aside a father's child support obligation because the trial court failed to make a written finding of the gross income of the father and the mother as required by O.C.G.A. § 19-6-15(a), or of the presence or absence of special circumstances justifying a departure from the guidelines applicable range as required by O.C.G.A. § 19-6-15(c). Eleazer v. Eleazer, 275 Ga. 482, 569 S.E.2d 521 (2002).

Trial court erred in not fully adopting the recommendation of the Department of Human Resources to reduce a father's child support obligation to $718 per month and in ordering that the father's child support obligation be reduced to $1,000 per month because the trial court's written order failed to state how application of the presumptive amount of child support would be unjust or inappropriate and how the best interest of the children for whom support was being determined would be served by the deviation pursuant to O.C.G.A. § 19-6-15(c)(2)(E) and (i)(1)(B); O.C.G.A. § 19-11-12(e) does not authorize the trial court to refrain from written findings or any other compliance with § 19-6-15 because like § 19-6-15(d), § 19-11-12(e) serves to emphasize that the qualitative determinations of whether special circumstances make the presumptive amount of child support excessive or inadequate and whether deviating from the presumptive amount serves the best interest of the child are committed to the discretion of the court. Spurlock v. Dep't of Human Res., 286 Ga. 512, 690 S.E.2d 378 (2010).

Juvenile court erred in awarding child support without making the written findings required by O.C.G.A. § 19-6-15(c)(2), including a determination of the parents' gross income and certain findings regarding the child's health insurance coverage and apportionment of the child's uninsured health care expenses. Roberts v. Tharp, 286 Ga. 579, 690 S.E.2d 404 (2010).

While there was evidence to support the trial court's application of a parenting-time deviation in the mother's favor in the amount of $300 because the father did not exercise visitation for the four and one-half years leading up to the hearing, the trial court did not incorporate the court's findings into the court's final order and, thus, remand for the court to enter appropriate factual findings, supported by the record, was required. Perez v. Cunningham, 355 Ga. App. 393, 844 S.E.2d 253 (2020).

- Trial court erred in omitting the amount of health insurance premiums and all work-related child care expenses the parent was paying from the child support worksheet. Bridger v. Franze, 348 Ga. App. 227, 820 S.E.2d 223 (2018).

- When a final child support order included a specific deviation for extraordinary educational expenses under O.C.G.A. § 19-6-15(i)(2)(J)(i), but the trial court failed to make the statutorily required written findings necessary to support the deviation, remand was required for a redetermination of the order, with any deviation to be based upon proper written findings. Brogdon v. Brogdon, 290 Ga. 618, 723 S.E.2d 421 (2012).

- Order of modification deviating from the presumptive child support obligation was flawed because the modification failed to comply with the statutory requirements of supporting findings and documentation for a discretionary downward deviation in the amount of child support. Crook v. Crook, 293 Ga. 867, 750 S.E.2d 334 (2013).

In a child support case, although both parties waived findings of fact, the trial court in deviating from the child support guidelines was nevertheless required to set forth how application of the guidelines would be unjust or inappropriate, or how the best interests of the children would be served by a deviation, under O.C.G.A. § 19-6-15(c)(2)(E). Wallace v. Wallace, 296 Ga. 307, 766 S.E.2d 452 (2014).

In action concerning child custody and child support, the trial court's final order had to be reversed because the order did not contain the requisite findings of fact to support the court's conclusions regarding child support and there was no child support worksheet or schedules attached to the order as required by O.C.G.A. § 19-6-15(c)(2)(E). Black v. Ferlingere, 333 Ga. App. 789, 777 S.E.2d 268 (2015).

Written finding of fact not required when the court orders the statutory presumptive amount. If no deviation applies and the trial court or jury decides not to deviate from the presumptive amount of child support, then the order need not explain how the trial court or jury reached that decision. Hamlin v. Ramey, 291 Ga. App. 222, 661 S.E.2d 593 (2008).

Father failed to show that a trial court's determination that the mother had no monthly gross income constituted a "deviation" that required the trial court to make findings of fact under O.C.G.A. § 19-6-15. The statute contemplated that a deviation was an increase or decrease from the presumptive amount of child support. Kennedy v. Kennedy, 309 Ga. App. 590, 711 S.E.2d 103 (2011).

In a divorce action in which the mother earned $5,097 monthly and the father earned $54,732 monthly, the trial court in granting a $2,000 upward deviation from the presumptive amount of support failed to explain how the guidelines amount would be unjust or inappropriate and how the best interest of the children was served by deviation as required by O.C.G.A. § 19-6-15(c)(2)(E)(iii); remand was required for such written findings. Fladger v. Fladger, 296 Ga. 145, 765 S.E.2d 354 (2014).

Trial court erred by failing to include findings in the court's child support award as to the court's deviation from the presumptive amount of child support based on the parent's military deployment. Carr-MacArthur v. Carr, 296 Ga. 30, 764 S.E.2d 840 (2014).

- Award was vacated and the case remanded after the trial court awarded child support without making a written finding as to the gross incomes of the child's parents, without applying the applicable statutory percentage range, and without making a written finding of special circumstances justifying the departure from the guidelines' applicable range. Urquhart v. Urquhart, 272 Ga. 548, 533 S.E.2d 80 (2000).

Georgia Supreme Court has noted that an award of child support may be based on the earning capacity of the obligor and not on gross income in certain circumstances; but it is also apparent that the obligor's gross income is the starting point for a child support determination under O.C.G.A. § 19-6-15(b). However, an order awarding child support was vacated since the trial court failed to determine the father's gross income, but made a child support award based on the earning capacity of the father; therefore, the section of the child support award as to attorney fees and the fees of the guardian ad litem was also vacated inasmuch as the trial court made these determinations in the context of the court's ruling awarding child support. Eldridge v. Ireland, 259 Ga. App. 44, 576 S.E.2d 44 (2002).

O.C.G.A. § 19-6-15(a) requires a divorce decree to include a written finding of the gross income of the father and the mother; when the decree included a finding of the husband's income, but did not include a finding of the wife's income, it was necessary that the case be remanded to the trial court with direction to make a finding of the wife's income, to reconsider the award of child support based on that finding, and to amend the decree accordingly. Southerland v. Southerland, 278 Ga. 188, 598 S.E.2d 442 (2004).

Because the trial court's order failed to specify the amount of child support to be paid, include a written finding of the gross income of each parent, and discuss the presence or absence of special circumstances in accordance with O.C.G.A. § 19-6-15(c), the failure to include these requisite findings constituted reversible error. Simmons v. Williams, 290 Ga. App. 644, 660 S.E.2d 435 (2008).

- Trial court adhered to the child support obligation table and, thus, pursuant to O.C.G.A. § 19-6-15(i)(1)(B), was not required to make any fact findings or explain the court's decision to forego applying the children's private school tuition to the child support calculations. Johnson v. Johnson, 284 Ga. 366, 667 S.E.2d 350 (2008).

- Although in making adjustments to a mother's income for other qualified children, the trial court was not required to make the type of findings that would support a deviation from presumptive child support, the trial court erred in not making findings regarding the child's best interests under O.C.G.A. § 19-6-15(f)(5)(C). Wheeler v. Akins, 327 Ga. App. 830, 761 S.E.2d 383 (2014).

- Trial court erred by failing to support the court's deviation from the child-support guidelines with findings of fact and, therefore, the ruling was vacated and the case remanded because the court awarded the father primary custody but split the custodial time fairly evenly, but after noting the parents' respective incomes, the trial court determined that neither parent would pay child support without ever stating what the presumptive amount of child support would have been. The court then, rather cursorily, claimed that this deviation from the unstated presumptive amount was in the best interests of the child because the deviation would allow the mother to better meet the child's needs when in her custody. Spruell v. Spruell, Ga. App. , S.E.2d (Sept. 18, 2020).

Court may include in decree provision for educational funds including expenses for attending a college during minority when the circumstances of the case warrant it. Coleman v. Coleman, 240 Ga. 417, 240 S.E.2d 870 (1977).

- Jury is not prohibited from providing for the education of minor children of an unsuccessful marriage. Bateman v. Bateman, 224 Ga. 20, 159 S.E.2d 387 (1968).

- Trial court did not err in leaving the children's private school tuition out of the court's child support calculations because, under O.C.G.A. § 19-6-15(i)(2)(J)(i), extraordinary educational expenses were not required to be factored into that calculation. Johnson v. Johnson, 284 Ga. 366, 667 S.E.2d 350 (2008).

Verdict merely finding amount for education of child is contrary to law. While it would scarcely be possible to educate a child without supporting the child, such a verdict leaves the question of support undecided and in such case a new trial should be granted. Flynn v. Flynn, 149 Ga. 693, 101 S.E. 806 (1920); Bateman v. Bateman, 224 Ga. 20, 159 S.E.2d 387 (1968).

- Trial court's order regarding child support did not comply with O.C.G.A. § 19-6-15(c)(2)(E) and (i)(1)(B) because the order failed to include the necessary findings; the trial court's award of tuition outside of the support award was an unexplained deviation. Johnson v. Ware, 313 Ga. App. 774, 723 S.E.2d 18 (2012).

- Any obligation to pay educational expenses of a child imposed by the decree terminates when the child reaches majority or marries. Coleman v. Coleman, 240 Ga. 417, 240 S.E.2d 870 (1977).

- In determining the amount of child support to be paid, the trial court can give consideration to indirect costs paid by the obligor, e.g., health insurance premiums, in departing from guidelines, but such indirect payments can be considered only to vary the final award. Ehlers v. Ehlers, 264 Ga. 668, 449 S.E.2d 840 (1994).

- Modification action to extend support payments to allow a child who had reached the age of majority to complete a secondary school education was not required to be filed before the child's 18th birthday. Ferguson v. Ferguson, 267 Ga. 886, 485 S.E.2d 475 (1997).

In order to extend support payments to allow a child who had reached the age of majority to complete a secondary school education, it was not required that provision for such possibility have been made in the temporary or final support order. Ferguson v. Ferguson, 267 Ga. 886, 485 S.E.2d 475 (1997).

- Because the superior court erroneously focused on a son's absences, tardiness, and failure to attend summer school when the court concluded that the son was not a "continuous full time student" when the son reached the age of majority, the decision was not in accord with the parties' agreement or the legislative purpose of O.C.G.A. § 19-6-15. Bullard v. Swafford, 279 Ga. 577, 619 S.E.2d 665 (2005).

Trial court erred when the court determined that a father's child-support obligation terminated because the child was not enrolled in and attending school on a full-time basis between June and August because the agreement between the father and the mother did not require the child's continuous attendance in school during the summer months but required only the child's full-time attendance in school; full-time school does not require attendance in school during the summer months. Draughn v. Draughn, 288 Ga. 734, 707 S.E.2d 52 (2011).

- Trial court erred in finding that a child's enrollment in online courses did not satisfy a modification order's requirement that the child "attend" school in order to have the father pay child support beyond the child's attainment of majority; once a child enrolls in approved online courses in an effort to graduate from a secondary school, the child's online attendance constitutes "attending school" for purposes of extending child support beyond the child's attainment of the age of majority. Draughn v. Draughn, 288 Ga. 734, 707 S.E.2d 52 (2011).

- Res judicata did not bar a father's claim for interpretation and enforcement of child support provisions in the parties' settlement agreement; the agreement clearly gave the father final authority over the children's school and the mother, as custodial parent, was obligated to pay the children's tuition from the support she received. Hardman v. Hardman, 295 Ga. 732, 763 S.E.2d 861 (2014).

- For purposes of the child support award, the juvenile court erred in considering free tuition that the mother received through the mother's employer as a fringe benefit to be included in the mother's gross income as the tuition benefit did not significantly reduce the mother's personal living expenses. Noble v. Noble, 345 Ga. App. 799, 815 S.E.2d 150 (2018).

RESEARCH REFERENCES

Am. Jur. 2d.

- 24A Am. Jur. 2d, Divorce and Separation, § 939 et seq.

- 27C C.J.S., Divorce, § 1137 et seq.

- Liability of parent for necessaries furnished to adult child, 42 A.L.R. 150.

Duty of father to support child as affected by decree which awards general custody to him, but permits mother to have custody part of time, 52 A.L.R. 286.

Education as element in allowance for benefit of child in decree of divorce or separation, 133 A.L.R. 902; 56 A.L.R.2d 1207.

Power of court in divorce or separation suit to provide for support of, or aid to, adult child, or to continue provision for support after child attains majority, 162 A.L.R. 1084.

Death of parent as affecting decree for support of child, 18 A.L.R.2d 1126.

Father's duty under divorce or separation decree to support child as affected by latter's induction into military service, 20 A.L.R.2d 1414.

Marriage of minor child as terminating support provisions in divorce or similar decree, 58 A.L.R.2d 355.

Father's liability for support of child furnished after entry of decree of absolute divorce not providing for support, 69 A.L.R.2d 203.

Opening or modification of divorce decree as to custody or support of child not provided for in the decree, 71 A.L.R.2d 1370.

Allocation or apportionment of previous combined award of alimony and child support, 78 A.L.R.2d 1110.

Propriety and effect of undivided award for support of more than one person, 2 A.L.R.3d 596.

Statutory family allowance to minor children as affected by previous agreement or judgment for their support, 6 A.L.R.3d 1387.

Power of court which denied divorce, legal separation, or annulment, to award custody or make provisions for support of child, 7 A.L.R.3d 1096.

Spouse's acceptance of payments under alimony or property settlement or child support provisions of divorce judgment as precluding appeal therefrom, 29 A.L.R.3d 1184.

Right of child to enforce provisions for his benefit in parents' separation or property settlement agreement, 34 A.L.R.3d 1357.

Income of child from other source as excusing parent's compliance with support provisions of divorce decree, 39 A.L.R.3d 1292.

Divorce: provision in decree that one party obtain or maintain life insurance for benefit of other party or child, 59 A.L.R.3d 9.

Father's liability for support of child furnished after divorce decree which awarded custody to mother but made no provision for support, 91 A.L.R.3d 530.

Propriety of decree in proceeding between divorced parents to determine mother's duty to pay support for children in custody of father, 98 A.L.R.3d 1146.

Responsibility of noncustodial divorced parent to pay for, or contribute to, costs of child's college education, 99 A.L.R.3d 322.

Validity and effect, as between former spouses, of agreement releasing parent from payment of child support provided for in an earlier divorce decree, 100 A.L.R.3d 1129.

Excessiveness or adequacy of money awarded as child support, 27 A.L.R.4th 864.

Excessiveness or adequacy of amount of money awarded for alimony and child support combined, 27 A.L.R.4th 1038.

What constitutes "extraordinary" or similar medical or dental expenses for purposes of divorce decree requiring one parent to pay such expenses for child in custody of other parent, 39 A.L.R.4th 502.

Death of obligor parent as affecting decree for support of child, 14 A.L.R.5th 557.

Consideration of obligated spouse's earnings from overtime or "second job" held in addition to regular full-time employment in fixing alimony or child support awards, 17 A.L.R.5th 143.

Treatment of depreciation expenses claimed for tax or accounting purposes in determining ability to pay child or spousal support, 28 A.L.R.5th 46.

Right to credit on child support payments for social security of other government dependency payments made for benefit of child, 34 A.L.R.5th 447.

Support provisions of judicial decree or order as limit of parent's liability for expenses of child, 35 A.L.R.5th 757.

Application of child-support guidelines to cases of joint-, split-, or similar shared-custody arrangements, 57 A.L.R.5th 389.

Consideration of obligor's personal- injury recovery or settlement in fixing alimony or child support, 59 A.L.R.5th 489.

Basis for imputing income for purpose of determining child support where obligor spouse is voluntarily unemployed or underemployed, 76 A.L.R.5th 191.

Right to credit on child support arrearages for time parties resided together after separation or divorce, 104 A.L.R.5th 605.

Right to credit against child support arrearages for time child spent in custody of noncustodial parent, other than for visitation or under court order without custodial parent's approval, 108 A.L.R.5th 359.

Right to credit against child support arrearages for time children spent in custody of noncustodial parent pursuant to visitation or court order, 118 A.L.R.5th 385.

Right to credit on child-support arrearages for money given directly to child, 119 A.L.R.5th 445.

Right to credit against child support arrearages for time child lived with noncustodial parent, other than for visitation or by court order, with approval of custodial parent, 120 A.L.R.5th 229.

Right to credit on child support for contributions to housing costs, utility bills, and other alleged household necessities made for child's benefit while child is not living with obligor parent, 123 A.L.R.5th 565.

Right to credit on child support arrearages for gifts to child, 124 A.L.R.5th 441.

Right to credit on child support for health insurance, medical, dental, and orthodontic expenses paid for child's benefit while child is not living with obligor parent, 1 A.L.R.6th 493.

Right to credit on child support for contributions to educational expenses of child while child is not living with obligor parent, 2 A.L.R.6th 439.

Right to credit on child support for contributions to travel expenses of child while child is not living with obligor parent, 3 A.L.R.6th 641.

Right to credit on child support for continued payments to custodial parent for child who has reached majority or otherwise become emancipated, 4 A.L.R.6th 531.

Validity, construction, and application of Child Support Recovery Act of 1992 (18 USCA § 228), 147 A.L.R. Fed. 1