Wilkinson v. Wilkinson (North Carolina 2021)

No. COA20-34 (N.C. Ct. App. 2021)
June 2021

Findings of fact must support any deviation from presumptive child support amount. The mother filed to modify child support. The father responded with a request for a decrease. He paid monthly support and made an annual payment based on a percentage of his bonus. The final order decreased both support and the percentage of the annual bonus payment, determined an overpayment of support, and changed the allocation of uninsured medical expenses and activities. The mother appealed. Since the trial court deviated from presumptive support, it was required to make specific findings. The appellate court found the order lacked these findings and reversed and remanded. The order lacked information about the determination of the father’s income. The appellate court found the arrears would need recalculated. The mother also made an argument about the calculation of her income. Again, the trial court’s decision lacked the proper findings for appellate review.