Tidwell v. Tidwell (Tennessee 2016)

A parent’s failure to raise the issue of voluntary/willful unemployment with respect to the other parent’s income is a waiver of this issue. In this case, even though the Father did not raise this issue at the trial level, the facts in the record supported the determination that Mother had no income at the time of the divorce, but that she was working toward a plan which would increase her earning power, and this would benefit all the parties in the future.