Craven County v. Hageb (North Carolina 2021)
Specific findings must support a court’s decisions in a child support proceeding. In this proceeding to establish paternity and support for two children, the father was self-employed. The final order set out his income and including these findings: the court reviewed tax returns, his income from a gaming and lottery business was not included in the calculation, and he had significant personal expenses on his tax return. In the final support award, the court gave the father credit for one of two additional children living with him, finding his name was only on the birth certificate for one child. The father appealed. The court of appeals reversed the order and remanded for additional findings. The court of appeals found the findings in the order lacked sufficient detail. The father argued he should have received credit for depreciation as an ordinary and necessary business expense. Depreciation can be handled in one of two ways. The findings in the order were not clear as to how the lower court treated the depreciation. The findings regarding credit for the additional children were also lacking. Parentage can be established in other ways. The lower court was free to find the father’s evidence not credible but the court still had to make findings to that effect.