In Bland v. Bland, 1999 ABQB 236, 48 R.F.L. (4th) 250, Burrows J. considered a number of factors in determining whether it was reasonable to require a parent to contribute to the cost of an extraordinary expense. Although not intended as an exhaustive list, these factors were set out in para. 24 and included: (a) the combined income of the parties; (b) the fact that two households must be maintained; (c) the percentage of the combined income represented by the expense; (d) any debt of the parties; (e) any prospect for the decline or increase in the parties’ means in the future (in Bland, the income of the parent from whom the contribution was sought was anticipated to decline by about 30% in near future); (f) whether that parent who had paid the expense in the past will be able to continue to do so without the contribution of the other parent; and (g) whether the parent from whom the contribution was sought was consulted about the expense before it was incurred.
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