Matthew A. Matthews v. Elizabeth McCall Northrup

Court of Appeals of Texas·Decided May 27, 2010·No. 01-09-00063-CV·Published

Opinion

Opinion issued May 27, 2010

In The

Court of Appeals

For The

First District of Texas


NO. 01-09-00063-CV


MATTHEW A. MATTHEWS, Appellant

V.

ELIZABETH MCCALL NORTHRUP, Appellee


On Appeal from the 245th District Court

Harris County, Texas

Trial Court Cause No. 2007-74804


MEMORANDUM OPINION ON REHEARHING

Appellant, Michael A. Matthews, has filed a motion for rehearing.  We requested a response from appellee, Elizabeth McCall Northrup, but received none.  Tex. R. App. P. 49.2.  We now grant Matthews’s motion for rehearing.  Tex. R. App. P. 49.3.  We vacate our January 14, 2010 judgment, withdraw our January 14, 2010 opinion, and substitute this opinion in its place.

Matthews challenges the trial court’s October 1, 2008 “Final Order in Suit Affecting the Parent-Child Relationship,” in which the trial court ordered child support in favor of Northrup.  In one issue, Matthews contends that the “trial court erred in including as income for the purposes of child support funds of the KLM Family Limited Partnership Revocable Management Trust.”

          We modify the judgment of the trial court and affirm as modified.

Factual and Procedural Background

Matthews, in his Original Petition in Suit Affecting the Parent-Child Relationship, sought joint managing conservatorship of his minor child and a determination of his child support obligation.  The parties stipulated to all facts but disagreed as to whether or not the trial court, in determining the amount of child support, could consider “phantom” income, i.e., income from the KLM Family Partnership, Ltd. (the “Partnership”) allocated to Matthews as a limited partner for federal income tax purposes, but not actually received by him.  Matthews’s mother, Leann Matthews (“Mother”), created the Partnership as a way to preserve family assets.  The Partnership, whose initial contributions were gifted by Mother, named two limited partners: (1) Matthews, with a 48.33 percent interest, and (2) his sister Kaci Ann Matthews, with a 49.67 percent interest.  Both Matthews and his sister were minors when the Partnership was created.  Mother held Matthews’s interest in the Partnership as custodian per the Texas Uniform Transfers to Minors Act (“UTMA”)[1] until he turned twenty-one years of age.

Mother also created the KLM Family Partnership, Ltd. Revocable Management Trust (the “Trust”), naming herself as Trustee and lifetime beneficiary and the limited partners in the Partnership as beneficiaries at her death.  She funded the Trust with ten dollars and the general partner interest in the Partnership, i.e., the remaining two percent interest.  She named the Trust as the general partner for the Partnership.  Mother controlled both the Trust and the Partnership in her capacity as Trustee, and any distributions were within her “express and total power” and her “sole discretion.”  The Trust provided that “[i]f any [T]rust property becomes distributable to a beneficiary when the beneficiary is under 21 years of age,” the “Trustee shall distribute the [T]rust property to a beneficiary when he or she attains 21 years of age.”  Matthews’s 2005 and 2006 federal tax returns reflect that he was allocated and paid taxes on income from the Partnership in the amounts of approximately $28,000 and $41,000, respectively.  However, neither the Trust nor the Partnership had made any actual distributions of money to Matthews as of the date of trial.

The trial court held a trial on the merits only on the issue of the “phantom” income.  A court reporter recorded the parties’ arguments, during which they referred to the Trust document, the Partnership Agreement, and stipulated facts, including as to income actually received and assets that did not produce income.[2]  No exhibits, however, were marked and handed to the court reporter for receipt into evidence.

After hearing the arguments of counsel, the trial court ordered the parties to provide further briefing on the issue of Matthews’s income from the Partnership.  Matthew attached to his trial brief the affidavit of Mother, who testified:

I have never declared a distribution, and I never will as long as I am the General Partner.  A distribution would be nothing more than contrary to my expressed intentions in creating the KLM Family Partnership, Ltd.  My son and daughter have never received any monies whatsoever from the KLM Family Partnership Ltd. and I do not intend to declare a distribution of any monies therefrom as long as I am alive.

In her trial brief, Northrup asserted that a court has the power to order the trustee of a trust to make disbursements for the support of a child to the extent that the trustee is required to make payments to a beneficiary who is required to make child support payments.  She noted that if disbursements are discretionary, the court may order child support payments from the income of the Trust.[3]  Northrup further asserted that the Trust terminated by its terms when Matthews turned twenty-one years of age, which triggered the clause that “all [T]rust property, including both income and principal was to be distributed to him when he became twenty-one years of age.”

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Matthew A. Matthews v. Elizabeth McCall Northrup, (Tex. Ct. App. 2010).

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