In Re The Marriage Of: Fanaye Ashagari v. Zeleke Kassahun, 75343-6

Zeleke Kassahun and Fanaye Ashagari divorced after a long marriage with three children; assets included a market and taxicab licenses. Kassahun allegedly withdrew large joint savings and received undocumented cash income.
At trial Kassahun reported modest wages on tax returns but testified to substantial untaxed cash receipts from taxicabs and the market; he paid personal expenses from business funds and produced limited records.
The trial court originally found Kassahun's gross monthly income at $13,750, ordered child support and $5,000/month maintenance, but this court remanded for more specific findings on gross monthly income.
On remand the trial court revised gross monthly income to $12,750, recalculated child support (increasing transfer amount slightly) but left maintenance at $5,000/month; Kassahun appealed the remand findings.
The Court of Appeals affirmed, holding (1) the trial court’s credibility findings and reliance on parties’ financial declarations were supported by substantial evidence, (2) expenditures and saving ability could be used to infer income, and (3) maintenance calculus complied with statutory factors.

Issue	Kassahun's Argument	Ashagari's Argument	Held
Whether trial court’s remand findings on Kassahun’s gross monthly income were supported by substantial evidence	Findings unsupported; court used incorrect values/methods and unreliable documents	Findings supported by Kassahun’s admissions, spending patterns, and parties’ financial declarations	Affirmed: substantial evidence supports findings and income calculation
Whether financial declarations/expenditures lacked required “other sufficient verification” under RCW 26.19.071(2)	Declarations were unverified and insufficient to prove expenses/income	Ashagari provided tax records, bank/credit records, checks and testimony as sufficient verification	Affirmed: trial court permissibly relied on submitted documents and testimony as other sufficient verification
Whether maintenance award misapplied statutory factors (RCW 26.09.090)	Award failed to fairly consider factors and was excessive given Kassahun’s claimed finances	Trial court properly considered earning capacity, resources, Ashagari’s needs and standard of living	Affirmed: trial court adequately considered statutory factors and did not abuse discretion
Whether court should have imputed income to Ashagari	(Raised for first time on this appeal) trial court erred by not imputing income	Trial court did not impute income; issue not raised earlier	Not considered on appeal: waived for failure to raise earlier

In re Marriage of Griffin, 114 Wn.2d 772 (court reviews dissolution decisions for manifest abuse of discretion)
In re Marriage of Landry, 103 Wn.2d 807 (same standard on review)
In re Marriage of Littlefield, 133 Wn.2d 39 (defines abuse of discretion / untenable grounds/reasons)
Bering v. Share, 106 Wn.2d 212 (findings supported by substantial evidence will not be disturbed)
Miller v. McCamish, 78 Wn.2d 821 (credibility determinations are for trial court)
State v. Gosby, 85 Wn.2d 758 (both direct and circumstantial evidence considered)
State v. Stenson, 132 Wn.2d 668 (unchallenged findings are verities on appeal)
In re Marriage of Trichak, 72 Wn. App. 21 (distinguishes reliable tax returns from estimates on financial affidavits)
In re Marriage of Mansour, 126 Wn. App. 1 (tax-return errors may render returns unreliable)