Alimony Modification Change of Financial Circumstances in Florida

Alimony Modification – Change of Financial Circumstances in Florida

An unanticipated change of circumstances, for purposes of modification of alimony, can be an unanticipated change in the size of the increase in the recipient’s income. “Additionally, no evidence was presented from which the trial court could conclude that the parties contemplated that the former wife would experience an income increase of this magnitude…See Kamenski v. Kamenski, 15 So. 3d 842,843 (Fla. 2d DCA 2009) (finding that a receiving spouse’s income increase from $17,500 at the time of the final judgment to $41,000 at the time of the petition for modification was an unanticipated and substantial change in circumstances where ‘neither the evidence presented nor the final judgment itself established that the parties contemplated that [the former wife] would experience an income increase of that magnitude)’.” Koski v. Koski.

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