Nunnally v. Nunnally (Tennessee 2017)
In a child support case, the court must have reliable evidence of income above a parent’s regular wages in order to include it in the income calculation. The trial court in this case calculated the parents’ incomes using only their hourly rates even though they testified to additional monthly income. The appellate court found no reliable evidence of the additional income. The parents filed a post-trial stipulation which contained income figures, and the father argued the court should have used those figures. However, the trial court lost jurisdiction once the appeal was filed and could not consider an already-litigated fact.