Divorce; Child support; Imputing income to a parent; The Michigan Child Support Formula (MCSF); 2017 MCSF 2.01(G)(1); Stallworth v. Stallworth; 2017 MCSF 2.01(G)(2)(a)-(k); Determining the income of self-employed individuals & business owners; 2017 MCSF 2.01(E)(1)(c); 2017 MCSF 2.01(D); 2017 MCSF 2.01(E)(4)(b) & (d); Deference to the trial court’s credibility findings; MCR 2.613(C); Woodington v. Shokoohi; Custody & parenting time; Motion for reconsideration; Yoost v. Caspari; MCR 2.119(F)(3); Admission of a videotape; Harmless error; MCR 2.613(A)

The court held that the trial court did not err in imputing income to defendant-father for child support purposes, that its decision to deny his motion for reconsideration did not fall outside the range of reasonable and principled outcomes, and that any error in admitting a videotape was harmless. Thus, it affirmed the divorce judgment, which granted plaintiff-mother physical custody of their children, “granted the parties joint legal custody, and ordered defendant to pay $1,445 a month in child support on the basis of an imputed annual income of $66,000.” The court was “not definitely and firmly convinced that the trial court made a mistake when it found that defendant was a farm manager.” It also rejected his claim “that the trial court did not consider his disabilities. The trial court specifically considered defendant’s testimony about his back and hand conditions that he gave at the aborted trial, but found that they did not prevent him from functioning in his capacity on the farm.” Further, it concluded that the trial court did not err in determining that he “had the ability to earn $66,000 a year.” He was an executive of his family’s farm “who had control over the form and manner of his compensation. He specifically testified that he refused monetary compensation from the farm. Defendant had extensive in-kind income.” While he stated that he had not drawn a paycheck for years, “he testified that he received housing, food, and clothing for the children as a benefit for the labor he provided on the farm. His parents paid” his electric and gas bills. The gas in his car was “paid for by a business credit card or his mother’s personal credit card. He had a business credit card in his name. Defendant also effectively reduced his compensation as a result of the complaint for divorce.” Given that he “received extensive alternative compensation for his work on the farm, and the average wage for a farm manager is $65,000 to $75,000,” the court was “not definitely and firmly convinced that the trial court made a mistake” in finding that he was able to earn $66,000 a year.