How has the Court in BC considered the family care allowance in the income of a foster care recipient for the purpose of calculating child support?

In Coleman v. Meyer, [1997] B.C.J. No. 2622, Master Horn included the tax‑free stipend for the care of foster children in the income of the recipient for the purpose of child support. In addition, Master Horn included a portion of a tax‑free family care allowance into the recipient’s income. He estimated what portion of the allowance was used for the foster child’s actual expenses and then he took into account the balance of the allowance as part of the recipient’s income because the evidence was that all the money was put into the family general household expense account and the foster child’s expenses were then paid from that account.

In Cole v. Cole, 2010 BCSC 1330, Butler J. decided that non‑taxable foster parent allowances, or some portion of them, were to be imputed in the father's Guideline income under s. 19. Since the father derived a significant portion of income from a source exempt from tax, s. 19(1)(b) and s. 19(1)(h) permitted the court to impute income to him to the extent he had additional income available for child support.