Skill: Draft Completed Colorado Child Support Guideline Worksheet (Form JDF 1820)
1. Subject-matter triage
- Treat the worksheet as the primary deliverable and the memo as secondary.
- Identify the governing forum, the child support guideline form version, the relevant parenting schedule, and all financial source documents before calculating.
- If the source set includes more than one parent, more than one income period, or more than one compensation type, enumerate each parent, period, and income stream before analysis.
- Separate baseline figures from corrected figures so the memo can explain what changed and why.
2. Failure modes the skill is correcting
- Using self-reported income without reconciling tax returns, pay records, K-1s, bank records, or other source documents.
- Missing discrepancies between stated income and documentary evidence, or failing to explain how each discrepancy affects the worksheet.
- Accepting rental income at face value without identifying non-deductible or support-irrelevant expense treatment.
- Ignoring potential income imputation when a parent appears voluntarily underemployed, or failing to anchor the analysis in the parent’s work history and market earning capacity.
- Using an atypical single year of bonus, equity, or other variable compensation instead of a representative averaging period.
- Misstating work-related childcare costs when provider invoices or contracts differ from party statements.
- Applying parenting time adjustments without checking the overnight schedule actually used by the form.
- Conflating advisory conclusions with arithmetic: the memo must explain legal treatment and downstream impact, not just restate numbers.
3. Legal frameworks / domain conventions that apply
- Colorado child support is governed by the income-shares framework in the Colorado Child Support Guidelines, including the statutes and form instructions applicable to the forum, commonly including C.R.S. § 14-10-115 and the current JDF 1820 instructions.
- Gross income for support purposes is broader than taxable income and may include wages, salary, commissions, bonuses, recurring equity compensation, rental income, self-employment income, pass-through income, and other recurring receipts recognized by the guideline.
- Rental income should be analyzed on a support basis, not merely a tax basis; ordinary and necessary expenses matter, but non-cash or otherwise non-support-relevant deductions require scrutiny.
- Voluntary underemployment requires an objective analysis of potential earning capacity using education, history, qualifications, prior earnings, and prevailing wage evidence; if imputation is warranted, the basis must be stated clearly.
- Variable compensation should be treated consistently with its recurring character; averaging over a representative period is generally more reliable than a single-year snapshot.
- Childcare costs included in the worksheet must be work-related and documented; source-provider records control when they conflict with a party’s estimate.
- Parenting time adjustments depend on the actual overnight allocation under the schedule, so the worksheet must reflect the operative schedule rather than a shorthand summary.
- If related-party benefits, below-market services, or similar economic advantages appear in the source record, analyze whether they function as income or offset support calculations under the governing guideline and forum practice.
- Every legal conclusion in the memo should identify the rule or authority supporting it, not merely assert the result.
4. Analytical scaffolds
Build a source-document inventory.
- List each parent, each income source, each tax year or pay period used, each childcare document, and the parenting schedule.
- If the source set is limited to one period or one parent for a particular issue, say so expressly and explain why.
Reconcile income by category.
- Start with the party’s stated figures.
- Compare them against source records.
- Identify each discrepancy, categorize it by income type, and state whether the worksheet should use the stated figure, a corrected figure, or an imputed figure.
Recalculate rental and self-employment income.
- Reconstruct gross receipts and ordinary operating expenses.
- Identify any deductions that do not reduce support income.
- State the corrected net figure and the reason each adjustment is made.
Assess imputation where underemployment is possible.
- Identify current role, work history, education, credentials, prior pay, and market wage evidence.
- Decide whether the underemployment appears voluntary under the governing standard.
- If imputation is appropriate, specify the support income figure and the basis for it.
Average variable compensation where appropriate.
- Identify bonuses, incentive pay, commissions, equity awards, or other non-base compensation.
- Determine the appropriate representative period from the source set.
- Use the averaged amount if that better captures recurring earning capacity.
Verify childcare and parenting-time inputs.
- Compare claimed childcare costs against provider records or invoices.
- Confirm the overnight schedule and the resulting parenting-time adjustment inputs.
- Flag any inconsistency between the schedule used on the worksheet and the schedule reflected in the source documents.
Produce two calculation views.
- Baseline worksheet: use the parties’ stated or initially reported figures.
- Corrected worksheet: incorporate all reconciliations, averages, imputed income determinations, and document-based childcare or parenting-time adjustments.
- Preserve the same form structure so the changes are auditable.
Draft the memo issue by issue.
- For each issue, state the discrepancy or legal question, the governing rule or guideline, the source documents reviewed, the recommended treatment, and the effect on the worksheet.
- Tie each issue to the relevant document evidence and the practical consequence for the support calculation.
- Include a closing recommendations section that translates the issues into action items for the preparer or reviewing attorney.
5. Vertical / structural / temporal relationships
- Track how changes to one input flow through the worksheet: income changes affect combined income, proportional shares, basic obligation, and any downstream adjustments.
- Preserve the sequence of time-sensitive data; do not mix annual, monthly, and periodic compensation without converting them consistently.
- If multiple years or multiple periods are in the record, analyze them in chronological order and explain any trend, anomaly, or representative averaging choice.
- Where one document supersedes another, use the later or more specific document only if it actually resolves the discrepancy; otherwise note the conflict in the memo.
- If the parenting schedule and the financial documents are inconsistent about household arrangements, flag the inconsistency rather than assuming a correction.
6. Output structure conventions
- Draft the worksheet as a completed Colorado guideline form with the operative case-caption fields and the income/adjustment entries needed to make the calculation intelligible.
- Include both baseline and corrected calculations if the record supports a before-and-after comparison.
- Draft the issues memorandum as a numbered list of distinct issues with a severity label on each entry using a consistent ordinal scale defined once at the start.
- For each memo issue, include: the issue, controlling authority or guideline, the source documents relied on, the recommended treatment, and the impact on the support result.
- End the memorandum with a concise Recommended Actions section that states what should be changed, who should do it, and when it should be done relative to filing or finalizing the worksheet.
- Deliver the worksheet first and the memo second; both must be complete and non-empty.