James Bogner v. Teresa Bogner, 16 N.E.3d 1031

Parents married in 2002; one child, H.B. (born 2005); dissolution in 2007.
Original support order: Father $162/week; alternate tax dependency; 158 overnight visits per year added in 2007.
2009 modification reduced to $135/week; daycare costs acknowledged; Father paid 60% of daycare.
2011 move to Valparaiso increased Father’s parenting time; Father provided meals/clothes beyond obligations; still $135/week.
2013 Father petitioned to modify to reflect decreased daycare; parties used 141–145 overnights; worksheet recommended $59/week; no daycare expenses.
Trial court deviated to $105/week citing “unjust” results; Father appeals alleging misuse of worksheet and improper tax-exemption modification; Court reverses and remands on both issues to $59/week and to re-evaluate tax exemption.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion in modifying child support.	Bogner argues deviation from worksheet to $105 unjust.	Bogner contends deviation warranted by tax credits and costs.	Abuse of discretion; should be $59/week per worksheet.
Whether trial court abused discretion in modifying tax exemption.	Bogner contends court failed to evaluate tax-exemption impact.	Mother asserts need to consider tax-exemption value.	Abuse of discretion; remand to re-evaluate factors.

Cross v. Cross, 891 N.E.2d 635 (Ind. Ct. App. 2008) (appellate review of child support deviations; abuse of discretion standard)
Garrod v. Garrod, 655 N.E.2d 336 (Ind. 1995) (flexibility in applying Child Support Guidelines; deviations allowed)
Eppler v. Eppler, 837 N.E.2d 167 (Ind. Ct. App. 2005) (guidelines aim for equitable support; not immutable)
Carpenter v. Carpenter, 891 N.E.2d 587 (Ind. Ct. App. 2008) (tax exemptions; factors to consider when waiving exemption)
Young v. Young, 891 N.E.2d 1045 (Ind. 2008) (overseas overnight credit; impact on support obligations)