calculate the amount of income that should be imputed to father because of his voluntary unemployment. After considering the evidence and the factors, the court may add “ ‘a just and appropriate amount [to] the amount reflected in Code § 20-108.2,’ accompanied by the requisite written findings,” Brooks, 18 Va.App. at 592, 445 S.E.2d at 729 (alteration in original) (quoting Richardson, 12 Va.App. at 20, 401 S.E.2d at 895), or the court may conclude that deviation from the presumptive guidelines is not appropriate in this case. III. CONCLUSION Because the court erred by not considering recent past earnings when deciding whether father’s voluntary unemployment should result in deviation from the presumptive guidelines, we reverse the court’s child support award a 5 S.E.2d 748, 753 (2008) (<HOLDING>); Reece v. Reece, 22 Va.App. 368, 376-77, 470
holding that appellants complaint on appeal that the environment was coercive did not change the fact that he was not in custody when he voluntarily went to the police station was told several times he could leave and did leave after the interrogation holding that father being held in jail based on presumption of ability to comply could not have been incarcerated for civil contempt of child support order after failing to appear at contempt hearing without affirmative finding based on evidence that he had present ability to pay purge amount holding that custody decision based on race is not justified holding the trial court made sufficient findings where it found in summary that father was physically able to make the required payments by virtue of his ability to work and earn income that he had the present financial ability to work and earn income that he had the present financial ability to satisfy his arrearage or to obtain the means by which said arrearage could be satisfied and that father failed to present adequate facts to excuse his noncompliance and inability to comply holding that a father was not voluntarily underemployed when he based his employment decision on ability to maintain custody arrangements