Hall v. Hall (Nebraska 2019)

A parent must provide specific evidence of income for child support but it can come from several sources. The mother filed a motion to modify custody and support. The district court denied the modification of custody and increased mother’s child support. It found mother’s income had increased and credited her with a fewer number of visitation days. The mother appealed the support modification. She argued that the father hadn’t presented evidence of his income, was voluntarily underemployed, and that the court used fewer days when crediting her for visitation for support. The appellate court affirmed in part and reversed in part. The appellate court found sufficient evidence of the father’s income. The father testified as to his income, he submitted an exhibit with a paystub attached, and both parents used the same figure in their proposed worksheets. Because the district court didn’t modify custody, the appellate court found it erred in crediting the mother with a different number of visitation days on the child support worksheet. It reversed for a recalculation of support.