Sable v. Sable, 2013 Ohio 2635

Brenda Sable and Michael Sable married on April 5, 1985; they have one son born February 1, 2004.
The divorce action was filed December 14, 2011; a separation agreement resolved most issues but not visitation, tax exemption, and real estate value.
An evidentiary hearing on those disputed issues occurred on September 27, 2012.
Judgment of Divorce entered November 20, 2012: extended visitation for appellee three weekdays 3:00–7:00 p.m.; appellee awarded the tax exemption for the child; real estate valued at $85,000 with equity $16,000; appellee ordered to pay appellant $8,000 for her share.
Appellant contends three errors: extended visitation disruption, improper tax exemption allocation, and lack of scheduled payment for equity share.
This appeal affirms the trial court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Visitation discretion and disruption	Extended visitation disrupts child's school schedule.	Trial court's visitation decision falls within discretion and is reasonable.	No abuse of discretion; order affirmed.
Tax exemption allocation	Tax exemption awarded to appellee was not requested and documents were not reviewed.	Court considered best interests and net tax savings among factors; disparity supports award.	No abuse of discretion; order affirmed.
Equity payment timing	Trial court failed to establish a payment schedule for equity buyout.	Judgment ties payment timing to overall property transfer timeline; issue ripe if not paid later.	Claim overruled; judgment affirmed.

Booth v. Booth, 44 Ohio St.3d 142 (1989) (visitation decisions reviewed for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard clarified)
Corple v. Corple, 123 Ohio App.3d 31 (1997) (best interests and tax exemption considerations)
Bobo v. Jewell, 38 Ohio St.3d 330 (1988) (net tax savings and best interest standard for exemptions)
Singer v. Dickinson, 63 Ohio St.3d 408 (1992) (net tax savings as factor in determining exemption)