In re Makinna B. (Tennessee 2019)
A parent must provide evidence of the cost of work-related childcare in order to get credit for it in a child support calculation. The mother and father had one child, and the mother was the primary residential parent. A few months after entry of the initial order, the father filed for modification, requesting custody of his daughter. The juvenile court granted his petition and modified child support accordingly. The mother appealed both the change of custody and the child support calculation. With respect to child support, she argued that there was no evidence to support the credit for childcare expenses. The appellate court agreed with the mother and reversed the decision. The appellate court found that there must be evidence in the record of the actual cost of childcare. The father included the cost on his worksheet without providing proof during the hearing.