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Missouri Case Law Development: Presumed correct child support regarding daycare

Presumed correct support amount even if daycare paid separately. John Mitalovich, Appellant, v. Tammy Lee Toomey, Respondent, No. 87755 (Mo. App. E.D., November 21, 2006, Ahrens, P.J.
This summary is strictly for the purpose of noting the proper findings in a judgment as to the presumed correct support amount for child support when work-related child care costs are being paid separately by the parties.
Form 14 provides for allocation of the reasonable work-related child care costs of the custodial parent. Harrison v. Harrison, 871 S.W.2d 644 (Mo. App. 1994). In the present case, the trial court was required to either allocate that child care cost in conformity with the Form 14, or make a finding that the award of such an amount was unjust or inappropriate. Id. The trial court found that mother required daycare for the minor child, and there was evidence in the record to support this testimony. Therefore, the court was required to include that cost in the Form 14 calculation. (Emphasis added).