Several decisions include receipt of financial contributions from the paramour to the payee ex-spouse as a factor to be considered. See Schweider, 243 Va. at 248-49, 415 S.E.2d at 137; Frey, 14 Va. App. at 275, 416 S.E.2d at 43;
see also Petachenko, 232 Va. at 299, 350 S.E.2d at 602. "Contributions to financial support by the paramour . . . tend to prove the assumption of duties or obligations attendant to marriage . . . ." Frey, 14 Va. App. at 275, 416 S.E.2d at 43.
See also Gordon, 675 A.2d at 548 (Maryland Court of Appeals found proof of shared assets and common bank accounts to be significant in determining cohabitation); cf.
In the Matter of the Marriage of Winningstad, 99 Ore. App. 682, 784 P.2d 101, 104 (Ore. App. 1989) (holding that without proof of such financial contribution, Oregon courts shall not terminate spousal support).