Cunningham v. Cunningham

548 A.2d 611, 378 Pa. Super. 280, 1988 Pa. Super. LEXIS 2951
CourtSupreme Court of Pennsylvania
DecidedSeptember 29, 1988
Docket672
StatusPublished
Cited by38 cases

This text of 548 A.2d 611 (Cunningham v. Cunningham) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cunningham v. Cunningham, 548 A.2d 611, 378 Pa. Super. 280, 1988 Pa. Super. LEXIS 2951 (Pa. 1988).

Opinions

BECK, Judge:

Reese and Mary Louise Cunningham were divorced after almost forty years of marriage. Extensive hearings were held before a master in divorce, who filed a report with his recommendations as to equitable distribution and alimony. Following review of the exceptions filed by Mr. Cunningham, the trial court issued an award of equitable distribution and alimony which Mr. Cunningham now challenges on appeal. We consider the issues he raises seriatim.

The standard by which we review an award of alimony and equitable distribution of marital property is abuse of discretion; unless the trial court has abused its discretion, we will not disturb its decision. Vajda v. Vajda, 337 Pa.Super. 573, 579, 487 A.2d 409, 412 (1985). We find that the trial court did not abuse its discretion and we affirm.

Mr. Cunningham first claims that the trial court erred in adopting the master’s finding that he had an income of $2,000 per month. Mr. Cunningham’s most recent income tax return showed a gross annual income of over $24,000, or approximately $2,000 per month. He claimed over $17,000 in deduction and depletion allowances. Mr. Cunningham challenges the trial court’s refusal to [282]*282deduct any of the $17,000 he claimed in depreciation and depletion expenses from his gross income in arriving at an estimate of his disposable income.

It is well established that depreciation and depletion expenses, permitted under federal income tax law without proof of actual loss, will not automatically be deducted from gross income for purposes of determining awards of alimony and equitable distribution. In determining the financial responsibilities of the parties to a dissolving marriage, the court looks to the actual disposable income of the parties:

[T]hat income must reflect actual available financial resources and not the oft-time fictional financial picture which develops as the result of depreciation deductions taken against ... income as permitted by the federal income tax laws. Otherwise put, “cash flow” ought to be considered and not federally taxed income.

Commonwealth ex rel. Hagerty v. Eyster, 286 Pa.Super. 562, 568-69, 429 A.2d 665, 668-69 (1981) (citations omitted). Accord, Flory v. Flory, 364 Pa.Super. 67, 527 A.2d 155 (1987); Parkinson v. Parkinson, 354 Pa.Super. 419, 512 A.2d 20 (1986).

Depreciation and depletion expenses should be deducted from gross income only where they reflect an actual reduction in the personal income of the party claiming the deductions, such as where, e.g., he or she actually expends funds to replace worn equipment or purchase new reserves. This is not the case here. Mr. Cunningham does not claim on appeal, nor did he claim below, that he in fact spent any of his $24,000 income to replace worn equipment or purchase new coal reserves. To the contrary, the couple’s daughter, an accountant who prepared a financial analysis of the Cunninghams’ coal company based on Mr. Cunningham’s 1984 income tax return, testified that the depreciation and depletion claimed by her father did not represent any actual expenditures on his part.1

[283]*283Second, Mr. Cunningham claims that the trial court erred in refusing to consider the testimony given at the October 31, 1986 hearing on his Petition for Reduction of Alimony Pendente Lite in determining its distribution of marital property and final award of alimony. This hearing was held after the master had closed his hearings and issued his recommendation to the trial court, but before the trial court issued its final order. Mr. Cunningham claims that testimony given at the October 31, 1986 hearing established that his income for the first seven months of 1986 was considerably lower than had been reported in earlier financial information filed with the court. Additionally, he claims that testimony at that hearing established that the rental income his wife was receiving had increased from $175 per month to $190 per month.

As to Mr. Cunningham’s income, the trial court did in fact consider his claim of decreased income in 1986. Even before Mr. Cunningham gave this testimony at the October 81 hearing, he had included this information in the Memorandum he filed with the master prior to the master’s rendering his report. The court found that Mr. Cunningham’s claims of reduced income were simply not credible, and adopted an income figure based on his 1984 income tax report. We will not disturb this determination of credibility on appeal.

The trial court did, however, refuse to consider the testimony given at the October 81 hearing regarding Mrs. Cunningham’s increased rental income, on the ground that such evidence was outside the record. See Eck v. Eck, 327 Pa.Super. 334, 475 A.2d 825 (1985). The trial court erred in [284]*284so concluding, as the transcript of the October 31 hearing on Mr. Cunningham’s petition for a reduction in alimony was in fact part of the official record in this action. We find that the trial court was correct on other grounds, however, and so affirm.

The respective roles of the master and the trial court in a divorce proceeding in which a master is used are set forth in Pa.R.Civ.P. 1920.55. This rule provides for a master to hear evidence and file his report and recommendations. The parties can then file exceptions to the master’s report, after which “the court shall hear argument on the exceptions and enter an appropriate final decree.” Pa. R.Civ.P. 1920.55(c) (Purdon 1987). This system suggests that, at least in counties in which no new hearing is held before the trial court, the trial court is limited to the evidence presented before the master. While the trial court is obliged to conduct a complete and independent review of the evidence when ruling on exceptions, Rollman v. Rollman, 280 Pa.Super. 399, 421 A.2d 755 (1980), its scope of review, like that of this court, is limited to the evidence received by the master.2

Mr. Cunningham next claims that the trial court erred in the valuations it placed on certain properties included in the award of equitable distribution. We disagree. A review of the record reveals that the master’s valuations, adopted by the trial court, were based on the testimony of the parties and their experts. We find that the trial court did not abuse its discretion in this regard.

Mr. Cunningham also claims that the trial court erred in failing to include in its assessment of Mrs. Cunningham’s current financial status various payments she may have received during the marriage (e.g., proceeds from the sale of jointly-owned property, mortgage payments, etc.). The trial court found that the payments in question [285]*285were received during the course of the marriage and were presumably properly disbursed during the course of the marriage. The trial court did not abuse its discretion in finding that Mrs. Cunningham could not be charged with current possession of these assets.

Finally, Mr.

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Bluebook (online)
548 A.2d 611, 378 Pa. Super. 280, 1988 Pa. Super. LEXIS 2951, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cunningham-v-cunningham-pa-1988.