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In Nebraska, the retained earnings of a closely held corporation may be included as income for child support purposes if the retained earning are "excessive or inappropriate." Pickrel v. Pickrel, 2006 Neb. App. LEXIS 96 (June 6, 2006). Similarly, in Maryland, sub-S corporate income should be included as income for child support purposes unless it is used to pay "ordinary and necessary business related investments" such as taxes on that income. Walker v. Grow, 2006 Md. App. LEXIS 78 (June 5, 2006). An Indiana court held that substituting alimony for child support impermissibly shorts the children because the obligee has to pay taxes on it. Dewbrew v. Dewbrew, 2006 Ind. App. LEXIS 1155 (June 20, 2006).
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Judicial Rulings 
