Background
Denise J. Craddock filed a 2021 parentage action concerning the parties’ two minor children. James L. Williams admitted parentage. The Douglas County circuit court initially ordered temporary support and later addressed permanent support, retroactive support, and parenting-time issues.
Williams worked for an information-technology company and the Army National Guard and owned two Missouri Airbnb properties. His tax filings reported Airbnb sales and rental income, but he claimed that the properties generated little or no income after expenses. The circuit court allowed deductions for certain supported expenses, including cleaning, utilities, maintenance and repairs, mortgage payments, and property taxes, but declined to deduct depreciation, travel, vehicle, and inadequately documented supply expenses.
The Court’s Holding
The Illinois Appellate Court, Fifth District, affirmed. It held that the circuit court did not abuse its discretion in calculating Williams’s net income for child-support purposes.
Illinois law defines net business income as gross receipts minus ordinary and necessary expenses required to operate the business. Although Williams claimed additional Schedule C and Schedule E expenses, he did not provide receipts, detailed testimony, or other evidence identifying the supplies or linking particular amounts to necessary Airbnb expenses. The trial court could therefore decline to deduct those amounts while recognizing the supported expenses it did allow.
Key Takeaways
- A parent seeking business-expense deductions from income for child support must support them with specific evidence.
- Tax-return entries alone did not require the court to treat claimed Airbnb supply expenses as ordinary and necessary.
- Child-support calculations are reviewed for abuse of discretion, with deference to the trial court’s assessment of evidence and credibility.
Why It Matters
The decision underscores that business owners cannot rely on generalized descriptions of expenses or tax classifications to reduce income for child-support purposes. Documentation and testimony connecting claimed expenditures to necessary business operations are critical.
The order was issued under Illinois Supreme Court Rule 23 and is nonprecedential except in the limited circumstances allowed by Rule 23(e)(1).