In Kelly v. Kelly, 341 Ark. 596, 19 S.W.3d 1 (Ark. 2000) the defendant, James E. Kelly, III, M.D., accepted a job paying $ 522,000 annually plus a bonus. 19 S.W.3d at 3. His bonus was based on a complicated formula, viz: The bonus amount shall be fifty percent (50%) of collections above a bonus threshold amount which shall equal physician's base salary plus Practice Site costs. Bonus compensation shall be pro-rated for any partial year. During the term of the Agreement Hospital and Physician will review the on-going practice site expenses as they relate to the calculation of the Bonus Percentage. Adjustments to the Bonus Percentage and Bonus Threshold will be made in accordance with the actual practice site experience Id. at 2. After the parties separated, Mrs. Kelly filed for divorce and asked for child support based on Dr. Kelly's salary plus bonus. Id. Ultimately, the Kellys agreed that Dr. Kelly would pay $ 6,000 per month child support. Id. at 3. The parties, however, asked the court to resolve the issue of what additional child support, if any, Mrs. Kelly should receive from Dr. Kelly's annual bonus. Id. At trial, Dr. Kelly testified that he had not received a bonus, and was unsure when a bonus might be paid or how much it might be. He indicated that the uncertainty came from the nature of the calculation formula, which included the business costs associated with his practice. He believed those costs would include the startup costs for practice, and that it would take an indefinite amount of time to build a practice. Id. at 3. The chancellor set Dr. Kelly's child support at $ 6,000 per month plus 25% of the net of any bonus he received. Id. at 2. The Supreme Court of Arkansas reversed because the court's child support order violated an Administrative Order in that it did not "establish a sum certain dollar amount." Id. In Arkansas, child support orders are governed by Section VII of Administrative Rule 10. Id. at 5. Under Rule 10, bonuses are considered income. The Arkansas Supreme Court said in Kelly: Calculating support from bonus income, like other forms of income, should be based upon a proper showing of past earnings and demonstrated future ability. For instance, with regard to self-employed payors, support is calculated based upon the previous year's federal and state income-tax returns and the quarterly estimates for the current year. Also, the court shall consider the amount the payor is capable of earning, or a net worth approach based upon property, life-style, etc. Administrative Order Number 10, III (c). Here, there is no history of bonus income, and the trial court acknowledged the uncertainty of whether [Dr. Kelly] would even qualify for a bonus in the foreseeable future given the business-expense calculation that would be required. We therefore reverse and remand for entry of an order consistent with this opinion. Id. at 7. In Kelly v. Kelly, the Arkansas Supreme Court discussed bonuses and held that the chancellor could not award a percentage of the father's future bonus income; however, the bonus, once given, becomes a part of that year's income. It explained: It is undisputed that the bonus income is income for child-support purposes under the definition of income contained in Administrative Order Number 10. However, James challenges the court's ability to presently order payments based upon indefinite, conditional income. Specifically, he contends that the court cannot "set and establish a sum certain dollar amount of support" where the receipt of the bonus is contingent upon the profitability of the clinic and the amount, if any, cannot presently be determined. We agree and reverse. ... Calculating support from bonus income, like other forms of income, should be based upon a proper showing of past earnings and demonstrated future ability. For instance, with regard to self-employed payors, support is calculated based upon the previous year's federal and state income-tax returns and the quarterly estimates for the current year. Also, the court shall consider the amount the payor is capable of earning, or a net worth approach based upon property, life-style, etc. Administrative Order Number 10 SECTION III(c). Here, there is no history of bonus income, and the trial court acknowledged the uncertainty of whether James would even qualify for a bonus in the foreseeable future given the business-expense calculation that would be required. (341 Ark. at 600, 19 S.W.3d at 4.)