The applicant mother brought a motion to change a 2013 final order to reduce her child support obligations effective January 1, 2016, due to a significant reduction in her income caused by mental health challenges and the sale of two of her dental practices.
The respondent father sought retroactive child support adjustments for 2013, 2014, and 2015, arguing the mother's income was higher than previously disclosed.
The court dismissed the father's claim for retroactive support, finding no material change in circumstances prior to 2016 and no blameworthy conduct by the mother.
The court determined the mother's income for support purposes from 2016 onwards by excluding non-recurring capital gains from the sale of her practices and applying a working capital analysis to her corporate income, resulting in a reduction of her ongoing child support obligations.