A spouse in a 30‑year common law relationship sought temporary spousal support following separation, alleging the respondent failed to make full financial disclosure and understated his income through a closely‑held corporation.
The respondent asserted a dramatic decline in business income and inability to pay support.
The court held that incomplete disclosure justified drawing an adverse inference and applying the Federal Child Support Guidelines methodology using the respondent’s three‑year average Line 150 income.
The court rejected the claimed current income and ordered temporary spousal support based on the historical income average, together with extensive disclosure obligations and valuation of the respondent’s business and income.
