again reexamine R.C. 3107.07(A). The recurring question that has continually presented itself to the appellate courts is: What percentage of support, from a parent’s total support obligation, will the judicial system allow before a determination is made that a parent’s consent is not necessary to allow an adoption to proceed. The lack of guidance from the Supreme Court of Ohio on this issue is glaring, as noted by Justice Douglas in his concurring opinion in Bovett, supra: “[T]his case presents us with an opportunity to decide what the language of the statute means concerning support and/or communication during the critical one-year period. I agree that this initial determination should be made by the probate judge and his or her judgment should not be 60, 5 OBR 156, 449 N.E.2d 511 (<HOLDING>); In re Adoption of Knight (1994), 97 Ohio
holding that parties not related to the child could not file an adoption petition and later prove the unfitness of the natural parents because the child was not available for adoption as defined in the adoption act parents had to be found unfit before petition could be filed holding the foster parents responsible for support where the childs natural parents are unknown and noting that an earlier new york case held that an agreement to adopt did not terminate the natural parents duty of support but that in that earlier case the natural parent was alive and capable of providing for the child holding that a single partial payment of 36 within the oneyear period prior to the filing of the adoption petition qualified as support and maintenance requiring natural parents consent as prerequisite to adoption holding that single partial payment of 20 within the oneyear period prior to the filing of the adoption petition was de minimis and did not make natural parents consent necessary for the adoption holding that natural parents consent for an adoption is required so long as the parent complies with the duty to support for any period during the oneyear preceding the filing of the adoption petition