Rayner v. Rayner, 2013 UT App 269

Marriage in 1981; separation in Jan 2010; Wife filed for divorce later that year.
Husband lost his job in 2008 and later had minimal income from a multi-level marketing firm.
Husband liquidated stock and retirement assets during separation; court imputed income and deemed dissipation.
Trial court found Husband underemployed with an $88k pre-loss salary and imputed $40k/year income for alimony calculations.
Court also found $116,096 dissipated in 2008–2010 and credited Wife accordingly in property distribution.
Appeal challenges both imputed income and dissipation findings as inadequately supported by detailed findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Imputed income proper given evidence?	Rayner contends evidence does not support voluntary underemployment.	Rayner argues job options and health permit more income; underemployment is supported by evidence.	Remand for detailed, explicit imputation findings.
Sufficiency of dissipation findings?	Rayner argues dissipated assets not adequately proven or quantified.	Wife asserts dissipation supported by asset liquidation and spending.	Remand for detailed findings and potential recalculation of division.

Goggin v. Goggin, 299 P.3d 1079 (Utah 2013) (affords broad discretion in property distribution and dissipation considerations)
Hall v. Hall, 858 P.2d 1018 (Utah Ct.App.1993) (requires detailed findings to support imputation of income)
Busche v. Busche, 272 P.3d 748 (Utah App. 2012) (imputation framework for determining earning capacity)
Fish v. Fish, 242 P.3d 787 (Utah App. 2010) (imputation analysis relevant to alimony calculations)
Willey v. Willey, 866 P.2d 547 (Utah Ct.App.1998) (discusses need for precise findings in imputation)
Parker v. Parker, 996 P.2d 565 (Utah App. 2000) (dissipation—burden-shifting framework and upper-limit estimation)
Rappleye v. Rappleye, 855 P.2d 260 (Utah Ct.App.1993) (requires sufficiently detailed dissipation findings when deviation from rules occurs)