Konkov

I. FACTUAL AND PROCEDURAL BACKGROUND

A. Marriage and dissolution Wife and husband were married in August 1997. They had two children, born in 1998 and 2000, and later commenced dissolution proceedings in 2009. B. 2016 settlement agreement On November 3, 2016, wife and husband entered into a stipulation and order to resolve various aspects of the dissolution proceedings (settlement agreement). The settlement agreement stated that the parties “intended to make a final and complete settlement and compromise of the support arrearages due to Husband and any and all claims pending by Wife incident to the dissolution of their marriage.” Pursuant to the settlement agreement, wife would make specified payments to husband over a period of four years, to be characterized as child support arrears. The total payment amount would vary depending on when wife made the payments—the more quickly she made the payments, the less she was required to pay. At a minimum, she could pay $150,000 by December 31, 2016; at a maximum, she was required to pay $182,500 by January 1, 2020. In exchange, and upon full satisfaction of payment by wife, husband agreed to waive rights to certain payments established…