15 Va. App. When based on the statutory factors, a court's support award will not be reversed absent an abuse of discretion. The wife's expense sheet, reflecting no expenditures for mortgage payments, was admitted as evidence in the case. It also provided for a credit to the husband, from proceeds obtained upon the sale of the marital residence, for mortgage payments he made in the intervening time. After the entry of the decree, the court granted husband's motion for financial relief, requiring wife to make the monthly mortgage payments, but summarily denied wife's motion to modify the support award without further hearing or argument.
Wife contends that the court erred in so doing.
The court's subsequent order requiring wife to pay the mortgage reapportioned the parties' relative financial postures, relative to needs and ability to pay. Contrary to the court's finding, the court's order constituted a material change in circumstances, requiring further inquiry to determine whether such change warranted a modification of support. The award of spousal support is therefore remanded for further proceedings consistent with this opinion. IV Wife next argues that the court erred by ordering her to pay one-half of husband's outstanding 1993 tax liability. She contends that the tax debt is separate property because husband filed a separate income tax return in 1993.