Warde and Warde (Child support)

This matter concerned appeals by both the father, Mr Warde, and the mother, Mrs Warde, against decisions of the Child Support Registrar. The father sought a departure determination under section 117 of the *Child Support (Registration and Collection) Act 1988* (Cth) to reduce his child support liability, while the mother sought to have the Registrar's decision regarding the adjusted taxable income of the father affirmed.

The primary legal issues before the court were whether the Registrar erred in refusing the father's application for a departure determination, specifically concerning the significant costs of childcare incurred by the father, and whether the Registrar correctly applied the father's adjusted taxable income in the child support assessment. The court was required to consider the provisions of the *Child Support (Registration and Collection) Act 1988* relating to departure from administrative assessments and the calculation of adjusted taxable income.

The court found that the Registrar had not erred in refusing the father's departure determination. While acknowledging the childcare costs, the court determined that these costs did not meet the threshold for a departure, as they were not considered an "unreasonable expense" in the context of the father's income and the child's needs. The court affirmed the Registrar's decision regarding the adjusted taxable income, finding that it had been correctly applied in accordance with the relevant legislative provisions. Consequently, the appeals were dismissed.