In re Marriage of Eastburg

Illinois Appellate Court
Civil Court
Child Support
Citation
Case Number: 
2016 IL App (3d) 150710
Decision Date: 
Thursday, October 13, 2016
District: 
3d Dist.
Division/County: 
Knox Co.
Holding: 
Affirmed.
Justice: 
SCHMIDT

In postdissolution proceedings, husband's federal income tax refund for 2014 was part of his net income for 2014, not an addition to it. Thus, husband's overwithholding did not affect his current child support computation, and court properly denied wife's motion to modify child support. Wife failed to disclose a straightforward account of her own income, and thus failed to support her argument that there was a substantial disparity in parties' incomes to justify modification of wife's obligation to pay minors' uninsured medical expenses. (O'BRIEN, concurring; CARTER, specially concurring.)