Smith v Smith & Anor

Smith v Smith & Anor

Capital allowances are to be deducted when calculating 'earnings' for child support purposes under paragraph 2A, using the figure for total taxable profits as submitted to the Inland Revenue; the appeal is allowed and the matter remitted for reassessment.

Parties
Appellant: Robert Smith; Respondent: Helen Smith; Respondent: Secretary of State for Work and Pensions
Jurisdiction
England and Wales
Judgment Date
19 October 2004
Procedural Posture
Appeal / Judgment on Appeal From Child Support Commissioner
Outcome
Appeal allowed
Legal Topics
Child Support, Maintenance Assessment, Self Employed Income Calculation, Statutory Interpretation

Case Brief

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Parties

Robert Smith

Appellant

Helen Smith

Respondent

Secretary of State for Work and Pensions

Respondent

Procedural Posture

Appeal / Judgment on Appeal From Child Support Commissioner

  1. 1 Whether capital allowances are deductible when calculating 'earnings' for child support purposes under the Child Support (Maintenance Assessments and Special Cases) Regulations 1992 as amended
  2. 2 Whether the parent with care must seek a departure direction if the formula produces hardship

Ratio Decidendi

Capital allowances are to be deducted when calculating 'earnings' for child support purposes under paragraph 2A, using the figure for total taxable profits as submitted to the Inland Revenue; the appeal is allowed and the matter remitted for reassessment.

Court Disposition

Appeal allowed

Orders

  • Matter remitted to the Appeal Tribunal for reassessment in light of this judgment
  • Tribunal to conduct necessary enquiries for any departure directions