Howe v. Howe
In Howe v. Howe, 30 Va. App. 207, 516 S.E.2d 240 (1999) the Court held that a $ 10,000.00 Christmas gift should be included in the father's gross income in determining modification of child support. It relied on the fact that gifts were explicitly included in the statutory definition of gross income, which includes "all income from all sources."
The Court noted that once the gift was included as income, the trial court had discretion to deviate from the presumptive guideline child support obligation if it would be unjust or inappropriate. Id. at 216, 516 S.E.2d at 245.