Can income be imputed to a parent who works under the table for cash and reports minimal income?

Yes. Courts are not bound by a parent's reported taxable income where there's credible evidence that their real earnings, including undeclared cash work, are significantly higher, and can impute income based on the actual economic reality rather than what appears on a tax return. Evidence typically comes from indirect sources, since cash work by its nature leaves a thinner paper trail: bank deposit patterns inconsistent with reported income, lifestyle and spending that don't match the declared earnings, witness evidence about the type and volume of work being done, or admissions made in other contexts.

Because this kind of income is deliberately hidden from tax authorities as well as from the family law proceeding, courts recognize that requiring the recipient to prove the exact dollar figure with precision would make the exercise practically impossible, so they can make a reasonable, evidence-based estimate rather than demanding exact proof. A parent who under-reports income to avoid taxes is not shielded from having that same conduct scrutinized in a support dispute; if anything, evidence of tax evasion can undermine their overall credibility with the court. Recipients pursuing this argument should gather whatever indirect evidence is available, since direct proof is rarely realistic in these situations.