Marriage of R.M. and P.N.

Summary

Mother was paid about $6,160 a month in IHSS wages for caring for her disabled adult daughter, and the trial court counted that as income in guideline support. The court of appeal held the needs-based public assistance exclusion in section 4058(c) did not apply, because the daughter's need set eligibility and Mother was a paid provider who submitted timesheets. It also held the trial court acted within its discretion in declining to impute income from Father's claimed $400,000 in crypto, collectible cars, and real estate, given his testimony about liquidity and the lack of evidence on values. Affirmed.

What it means for the financial analysis

When a payee parent is an IHSS provider, run the payments through the income analysis as wages. Tax-free status does not take them out, and if anything it raises the cash available for support. On the payor side, a list of assets does not become income. The record needs purchase prices, current values, liquidity, and the income the assets actually produce, or the court may reasonably decline to impute anything.

Also available on CourtListener.