Kathleen Noble and Stephen Noble, divorced parents of five children, disputed child support after a custody order placed one child primarily with the mother in New Hampshire and four children primarily with the father in Georgia. The juvenile court ordered the mother to pay $754 per month and awarded the father a substantial deviation from the presumptive support amount, based in part on the mother’s relocation. The Georgia Court of Appeals affirmed in part and reversed in part. It held that the court could treat the mother’s employment tuition benefit as income because the benefit reduced her living expenses, and that a written child-support judgment controls over an earlier oral pronouncement. But the court could not uphold the $1,377 deviation because the order did not make the findings required for a deviation under Georgia’s guidelines. The court otherwise rejected challenges involving visitation travel and health-insurance adjustments, applying the presumption that an untranscribed hearing contained evidence supporting the judgment. The case was remanded for reconsideration of the unsupported deviation.