Child support: leins, expenses and foreign exchange rate

Chart of exchange rates between various international currencies

Nzewunwah v. Nzewunwah COA 225-590

CONCLUSION: Trial court erred in calculating Father’s income, including work related expenses not supported by competent evidence and failing to adequately describe real property on which the court placed a child support lein. 


 After separation, Father quit a high paying job with an Exxon affiliate in Nigeria and moved to Atlanta, where he testified he was unable to find work. The trial court imputed his prior income, but erred in using the same exchange rate for retroactive and prospective income. It also granted expenses for a private school where the child had not yet been accepted, which was error. Arrears were reduced to a judgment and the court placed a lein on father’s real property, but failed to give a sufficiently detailed description. Father’s argument that the court erred by failing to separate costs directly related to the nanny vs. activity costs was abandoned because he included no citations.

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