efforts to optimize his salary. Rather, there must be substantive evidence to support a finding that the parent deliberately limited his or her earnings to avoid child support payments. See Peniston, 161 S.W.3d at 434; Atkinson, 947 S.W.2d at 834. Here, neither the record, nor the trial court’s judgment reflects any such evidence. In fact, the trial court found that Father had consistently worked full-time as an attorney from 1992 to the date of the judgment. Cf. Cross v. Cross, 318 S.W.3d 187, 192 (Mo.App.W.D.2010) (“The most common scenario for voluntary reduction of income without justification is where a parent deliberately quits work to reduce his or her child support [payments].” (quoting Peniston, 161 S.W.3d at 434)); Hoffman v. Hoffman, 423 S.W.3d 869, 877-78 (Mo.App.E.D.2014) (<HOLDING>). In sum, while the trial court may have found
holding that cyfd failed to present clear and convincing evidence that the causes and conditions of neglect were unlikely to change in the foreseeable future when the father complied with his treatment plan and cyfd failed to reevaluate the father following his release from prison 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 substantial evidence supported trial courts finding that father voluntarily reduced income without justification because father ran failed business had earned no income for several years before judgment and failed to seek other employment holding that a child was not barred by a former statute of limitations applicable to actions to establish the existence of a father and child relationship when the current action was to establish the nonexistence of a father and child relationship and the presumed father no longer persisted in maintaining paternity holding substantial evidence supported jury finding of abuse of process