Zipperer v. Zipperer

In Zipperer v. Zipperer, 567 So. 2d 916 (Fla. 1st DCA 1990), the First District Court of Appeal held that a spouse's undistributed business income fell within the general definition of income set forth in section 61.046 and thus was properly considered by the trial court in awarding alimony. See 567 So. 2d at 917. The First District rejected the argument that undistributed business income should not be considered income under chapter 61 because it was reported only for tax purposes and was not actually received by the payor spouse. See id. The First District noted that income is broadly defined in section 61.046 to include "any form of payment to an individual, regardless of source." Id. (quoting 61.046(4), Fla. Stat.).