Hall, A. v. Bartron, J., III, 321 A.3d 1047

Alicia M. Hall (Mother) appealed a child support order concerning support owed by Stark Bartron III (Father) for their 11-year-old child.
Father is majority owner (75%) and salaried employee of a closely-held corporation, Bartron Supply, Inc., which does not distribute profits to shareholders and pays for some personal expenses (perquisites) for Father (vehicle, cell, insurance).
Mother is unemployed due to injury, received a lump-sum settlement, and collects survivor benefits; she sought an upward modification of support after three years, citing increased income to Father from the corporation and other sources.
The domestic relations officer recommended higher support based on imputed corporate income to Father, excluding depreciation, but the trial court maintained the existing obligation after a de novo hearing.
On appeal, Mother challenged the trial court’s calculations regarding both parties’ incomes, particularly focusing on corporate profits, depreciation, rental income, and perquisites.
The Superior Court reviewed whether the trial court abused its discretion and properly applied legal standards to determine income for support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should corporate profits be imputed as Father's income?	Father is sheltering income by corporate retention, not genuine business need.	Profits are retained out of business necessity per contract obligations and expert testimony.	No abuse of discretion — profits retention was justified.
Should depreciation deductions be excluded from income?	Depreciation deductions are reducing net income improperly — not all are necessary.	Deductions track historical business needs, vital to ongoing operations.	No abuse of discretion — deductions found reasonable.
Should rental income from business-owned properties count as Father's income?	Rental payments increase Father’s equity and benefit him financially.	Rent merely covers mortgage; no excess cash benefits Father; cash-flow neutral.	No abuse of discretion — cash-flow analysis supports exclusion.
Should personal perquisites be included as income?	Value of personal use of car, phone, possibly pension, should raise imputed income.	Unclear business vs. personal use; claimed mostly business; pension may be mandatory.	Trial court erred — must value perquisites and add to income; remanded.
Was Mother’s settlement properly annualized as income?	Lump sum supports her entire lifetime, not just until child’s majority.	Court acted within discretion in annualizing until child’s adulthood.	No abuse of discretion — method was within trial court's discretion.

Labar v. Labar, 731 A.2d 1252 (Pa. 1999) (Obligor’s available cash flow, not taxable income, governs support calculations)
Fennell v. Fennell, 753 A.2d 866 (Pa. Super. 2000) (Business owner must show income retention is necessary for business to avoid additional support)
Mascaro v. Mascaro, 803 A.2d 1186 (Pa. 2002) (Personal perquisites from a business may be imputed as support income)
Sichelstiel v. Sichelstiel, 272 A.3d 530 (Pa. Super. 2022) (Standard of review in support order appellate proceedings)