In re Marriage of Siddiqui, 2025 IL App (3d) 220355-U

1. Case citation and parties
- In re Marriage of Siddiqui, 2025 IL App (3d) 220355-U (Ill. App. Ct., 3d Dist., Mar. 24, 2025)
- Petitioner‑Appellant: Erum Siddiqui (mother); Respondent‑Appellee: Nabeel Noor (father).

2. Key legal issues
- Whether the circuit court’s factual findings (161 annual overnights and $750/month health‑insurance cost) supporting the child‑support calculation were supported by the evidence and consistent with the shared‑care formula (750 ILCS 5/505(a)(3.8)).
- Whether the court abused its discretion in (a) declining to award retroactive child support, (b) allocating joint responsibility for unpaid tax liabilities for 2017–2020, and (c) awarding attorney fees to the father arising from the mother’s abuse of parenting time.

3. Holding/outcome
- The appellate court held the circuit court’s factual findings underlying the child support determination were against the manifest weight of the evidence (requiring reversal/remand as to that portion).
- The court affirmed the trial court’s refusal to award retroactive child support, its order that both parties share responsibility for tax delinquencies for 2017–2020, and the award that the mother pay attorney fees related to her abuse of parenting time.

4. Significant legal reasoning
- Standard of review: child‑support determinations reviewed for abuse of discretion; underlying factual findings reversed only if against the manifest weight of the evidence.
- Overnights/insurance: The father’s calendars and testimony were flawed and the record did not support the trial court’s specific numeric findings (161 overnights; $750/month for insurance). The appellate court concluded the opposite inference was sufficiently supported to render the trial court’s factual findings unreasonable. The court relied on the evidentiary record (including a financial affidavit listing $400/month insurance and disputed overlap of vacation days) to find the child‑support facts unsupported.
- Retroactive support: The refusal to order retroactive support was within the trial court’s discretion (the father’s period of unemployment and other circumstances justified denying retroactivity).
- Tax debt and fees: Treating unpaid tax liabilities as a marital debt and allocating joint responsibility was not an abuse of discretion given the parties’ shared marital context and the father’s failure to file; sanctioning the mother (make‑up parenting days plus fees) for abusing parenting time was likewise a permissible exercise of discretion.

5. Practice implications
- Prove critical numeric facts: when shared‑care calculations hinge on overnight counts or insurance costs, introduce contemporaneous, corroborated evidence (detailed calendars, custody logs, insurer invoices, premium statements). Don’t rely on demonstrative calendars without foundation.
- Anticipate scrutiny of agreed‑term interpretations (vacation language) and present direct evidence resolving overlaps.
- If seeking retroactive support, develop record on parent’s earnings/ability to pay and child’s needs for the relevant period.
- Counsel should address tax‑filing defaults early: trial courts can treat unfiled returns/liabilities as marital debt.
- Use parenting‑time violations carefully—abuse can produce sanctions and fee awards; preserve objections and seek detailed findings and calculations in the judgment for appellate review.