In light of husband’s self‑employment as a board‑certified urologist, the significant fluctuations in his income over the past several years, and his failure to adequately document his actual income at the time of the final hearing, trial court’s decision to use an income‑averaging approach to calculate husband’s weekly gross income for child support purposes was not clear error.
Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her website. www.famlawconsult.com