Professor Charette then applied a sole dependency rate of 70%, a rate consistent with the results of expenditure analysis of North American households. Professor Charette then relied on Nielsen v. Kaufmann, which sets out the principle of net (or cross) dependency loss that might be applicable to some households. He stated that the following net dependency loss formula is consistent with Nielsen: 70% of after-tax income of spouse, less 30% of after-tax income of K.M.
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