Roth v. Roth (North Carolina 2022)

No. COA21-84 (N.C. Ct. App. 2022)
January 2022

The North Carolina child support guidelines define gross income from self-employment or operation of a business as gross receipts minus ordinary and necessary business expenses required for self-employment or business operation. The father requested a downward modification of his child support based on the parent’s custody schedule. The final order modified support, upwardly. The father appealed, arguing the court incorrectly determined his income. The appellate court affirmed. The father challenged the trial court’s inclusion of certain categories of expenses in his gross income, including expense reimbursements and depreciation. The appellate court found the trial court made detailed findings as to its calculation of the father’s income and found his arguments unpersuasive. In his testimony, the father didn’t explain the expenses or why they should qualify as appropriate business expenses.