In In re Marriage of Neal (1979) 92 Cal.App.3d 834, both parents were parties and litigated the issues of custody and child support. Neither party requested, but the court ordered, that the father "'shall claim the two minor children as dependents for income tax purposes.'" (Ibid.) The Neal court held, "'a party is entitled to "any and all relief which may be appropriate under the scope of his pleadings and within the facts alleged and proved, irrespective of the theory upon which they might be alleged."'" (Id. at p. 847.) The parties raised the issue of child support in the pleadings and in the extensive pretrial proceedings. Further, "'Circumstances to be considered by the trial judge in awarding . . . child support are the needs of the parties and the ability to meet those needs, including property owned, obligations to be met, ability to earn and actual earnings.'" The father's income tax liability was an obligation which was therefore subject to consideration by the court. In all events, the issue of child support was contested throughout the proceedings. Thus, the trial court did not exceed its jurisdiction in making the tax order. (Ibid.)