The most prevalent "condition" in matrimonial cases for attorneys to overcome was always considered what we refer to as, R.A.I.D.S, or Recently Acquired Income Deficiency Syndrome, (see, Liotti, Thomas F., "Attorneys Must Become Aware of R.A.I.D.S.," The Attorney of Nassau County, December 1997 at 8 and 9); the conjured "affliction" where the monied spouse, usually the man, at the outset of a matrimonial case, claims that his income has suddenly fallen and his liabilities have risen. This is standard fare, and courts have responded to this problem by imputing income to the monied spouse.

Over the years the trial courts have acquired considerable discretion to impute income in fashioning support awards, and "a court is not required to find that a parent deliberately reduced his or her income to avoid a child support obligation before imputing income to that parent." See, Irene v. Irene, 41 AD3d 1179, 1180, 837 NYS2d 797 [4th Dept. 2007] [internal quotation marks omitted]; see, Matter of Bashir v. Brunner, 169 AD3d 1382, 1383, 93 NYS3d 481 [4th Dept. 2019]; Matter of Hurd v. Hurd, 303 AD2d 928, 928, 757 NYS2d 170 [4th Dept. 2003]). Moreover, courts may "'impute income based upon the party's past income or demonstrated earning potential'" (see, Matter of Taylor v. Benedict, 136 AD3d 1295, 1295, 24 NYS3d 546 [4th Dept. 2016]), and a court's discretionary determination to impute income "'will not be disturbed so long as there is record support for its determination'" See, Matter of Muok v. Muok, 138 AD3d 1458, 1459, 30 NYS3d 776 [4th Dept. 2016]).