Vlies v. Brookman


2005 WI App 158, 285 Wis. 2d 411, 701 N.W.2d 642 (WI Ct. App., 2005)


A circuit court must separately calculate child support and maintenance as a condition precedent to calculating family support. Unless the court deviates from the percentage guidelines, it must set family support at an amount that results in a net payment after taxes of no less than the child support calculated under the guidelines. Trial court reversed for not making factual findings for the exercise of its discretion for need and ability to pay.

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