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If my former spouse has a business, but transfers the business to his/her new spouse's name, can this be a basis to modify spous

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The case on point is, IRMO Berman (9-27-17). In this case, the husband retired at age 65, but opened a business and placed it in his new spouse’s name. He filed a motion to modify spousal support based on his retirement and claimed that the business was in his new spouse’s name and thus, the income from the business could not be used in calculating spousal support. The Court denied husband’s request to modify spousal support on the basis that the transfer of the business in the new spouse’s name was just a sham to try to get out of paying spousal support and the Court ruled that the income from the business could still be imputed to the husband for purposes of calculating spousal support.
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