Based on the precedent established in Marriage of Loh, for almost 20 years family law practitioners could rely on their client’s tax returns as being “presumptively correct” and establishing a starting point for the calculation of support. However Marriage of Hein (2020) upended this well-established presumption. The Hein court concluded that, in the case of self-employed individuals who wholly own a business (or businesses), the burden of proving expenses reflected on tax returns falls upon “the self-employed parent who controls the corporations.” This program will address when Hein applies and how to satisfy the heightened evidentiary burden created by Hein for self-employed parents, as well as subsequent cases which have addressed the holding in Hein.