Military Housing Should Be Included (or at least considered) in Income for Child Support Calculation

by Annette Burns on March 10, 2011

The Arizona Court of Appeals in Patterson v. Patterson rules that the value of military-provided, on-base housing might be included in a parent’s income for child support calculations, based on the court’s determination as to whether the value of that benefit is significant and reduces the parent’s living expenses.   The definition of “gross income” in the Guidelines is broad enough to include employment benefits received by a spouse “if they are significant and reduce personal living expenses.     The Court noted that this decision was entirely consistent with its holding in Hetherington (2008) as well as with numerous other jurisdictions on this issue.

For discussion the inclusion of other military benefits as income for support purposes, see also In re Marriage of Stanton, California 4th district, 2010.

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