The DC Court of Appeals in Saxon v. Zirkle, imputed income during the divorce proceedings for voluntary unemployment. Specifically, the trial court had granted parties absolute divorce while denying Ms. Saxon’s request for alimony and instead imputed income on her for unemployment, awarded the parties joint legal custody of their child, as well as modified Mr. Zirkle’s child-support obligations based on the imputed income. On appeal, Saxon challenged to the trial court’s decision to impute $24,000 in income to her in determining alimony and child support calculations. The issue of imputation of income arose during the alimony proceedings. Based on
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