September 2017 | No. M2016-00963-COA-R3-CV (Tenn. Ct. App. 2017)

Scobey v. Scobey (Tennessee 2017)

A parent must present evidence of their most recent actual income when determining income for a child support modification. The father requested a modification of his support and used outdated income information to calculate the new obligation. The trial court denied the modification and the appellate court upheld the decision. The appellate court found the one paystub father presented did not accurately reflect his current or future income and that his testimony was erroneous and unreliable.

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