In re Marriage of Salbi, 2023 IL App (2d) 230210-U

1) Case citation and parties
- In re Marriage of Hussain Salbi, No. 2-23-0210 (Ill. App. Ct., 2d Dist., Nov. 7, 2023) (Rule 23 order).
- Petitioner-Appellant: Hussain Salbi. Respondent-Appellee: Tamara Ali.

2) Key legal issues
- Whether the trial court erred in valuing the marital business (BSoft Solutions, Inc.).
- Whether the court’s determination of husband’s gross monthly income for support purposes was against the manifest weight of the evidence.
- Whether the division/allocation of the parties’ retirement accounts was erroneous.
- Whether the trial court abused its discretion in allocating parental responsibilities.

3) Holding/outcome
- Affirmed in all respects. The appellate court held: (1) no error in business valuation given lack of meaningful valuation evidence from the parties; (2) the court’s income finding was not against the manifest weight of the evidence; (3) an inadequate appellate record required presuming the trial court’s division of retirement accounts conformed to law and had sufficient factual basis; and (4) no abuse of discretion in the allocation of parental responsibilities.

4) Significant legal reasoning (concise)
- Business valuation: The parties failed to present meaningful, probative evidence of BSoft’s value (taxs, appraisals, or expert valuation testimony were lacking or inadequate), so the trial court’s valuation stood.
- Income: Husband consistently testified to a fixed monthly salary ($6,666.66) and evidence of compensation structure and corporate payments supported the trial court’s finding; conflicting testimony and lack of reliable contrary proof meant the trial court’s decision was not against the manifest weight.
- Retirement division: Appellant did not provide a sufficiently complete record on appeal (missing portions of the record that would show the trial court’s rationale and calculations). Under appellate presumptions, the trial court’s ruling is presumed correct absent record proof to the contrary.
- Parental responsibilities: The GAL’s investigations and supplemental report (including interviews and documentary review), plus in-camera interviews and trial testimony, supported awarding respondent majority parenting time and decision-making; trial court’s discretion was not abused.

5) Practice implications for family law attorneys
- When disputing a business valuation, produce timely, competent valuation evidence (expert report, business records reconciled to tax returns) and preserve admissions/explanations about loans, draws, and client pre-funds.
- For income determinations, present clear documentary support (tax returns, payroll records, corporate distributions, SBA loan/payment records) to overcome a trial court’s factual finding.
- Preserve a complete trial record if you intend to appeal—missing transcripts, orders, or exhibits can be fatal to appellate challenges (appellate courts will presume correctness).
- In custody/parenting disputes, the GAL’s detailed reports, in-camera child interviews, and consistent documentary proof are very persuasive; be proactive in discovery and in presenting evidence addressing children’s welfare.

Note: This is a Rule 23(b) non‑precedential order.