In re B.A.K.

Citations

• 2022 Ohio 1443

Syllabus

Potential income includes imputed income that a trial court determines the parent would have earned if fully employed. After finding that Father was underemployed, the magistrate was required to determine Father's potential income and use that number in calculating his support obligation. The trial court abused its discretion by adopting the magistrate's order finding Father underemployed without subsequently determining Father's potential income. The decision of whether to establish retroactive support is entrusted to the trial court's discretion. When completing the Child Support Computation Worksheet, the court shall exclude any reimbursed or subsidized childcare cost, including any state or federal tax credit, whether or not claimed. Hence, eligibility for the federal child care tax credit is the determinative factor for the court to consider when calculating a support obligation, not whether the tax credit was actually received.