Schweider, 243 Va. at 248, 415 S.E.2d at 137 (emphasis added) (quoting Johnson, 152 Va. at 970, 146 S.E. at 291).Cranwell v. Cranwell, 59 Va. App. 155, 162, 717 S.E.2d 797, 800 (2011) (other citations omitted). As Pellegrin indicates, the first factor is properly viewed as a threshold requirement, which is a necessary though perhaps not a sufficient condition for cohabitation. Pellegrin, 31 Va. App. at 764, 525 S.E.2d at 616 (acknowledging that a common residence is a "requirement" for cohabitation that "is firmly established in Virginia case law," but noting that "proof of a common or shared residence does not itself establish cohabitation").

Although a trial court may determine the weight to accord each factor, proof of a common residence is a threshold requirement, without which cohabitation cannot be established. Cranwell v. Cranwell, 59 Va. App. 155, 163 (2011). We have stated that "proof of a common or shared residence does not itself establish cohabitation."

Indeed, "if two individuals do not share a common residence, they are not cohabiting." Cranwell v. Cranwell, 59 Va. App. 155, 162, 717 S.E.2d 797, 800 (2011) (While "proof of a common . . . residence does not itself establish cohabitation," it is nevertheless a "requirement for cohabitation."). "Under [the above] framework," therefore, "a court seeking to determine whether a couple is cohabiting in a situation analogous to marriage must ask, first, whether the couple has 'established and shared a common residence.'"

As we have recently emphasized, "'the term "cohabit" means to live together in the same house as married persons live together, or in the manner of husband and wife.'" Cranwell v. Cranwell, 59 Va. App. 155, 161, 717 S.E.2d 797, 800 (2011) (quoting Schweider v. Schweider, 243 Va. 245, 248, 415 S.E.2d 135, 137 (1992)). Indeed, "[t]he requirement that the payee ex-spouse and that party's paramour be shown to have established and shared a common residence is firmly established in Virginia case law.

A threshold requirement for a finding of cohabitation is that the former spouse and another person actually share a common residence. Cranwell v. Cranwell, 59 Va. App. 155, 163, 717 S.E.2d 797, 800 (2011). Unquestionably, that requirement is met here.

This was error. See Cranwell v. Cranwell, 59 Va.App. 1155, 1166-67 (2011) ("The fact that certain sources of income may be irregular or not expected to continue in the future is irrelevant to a present calculation of the parties' income."). Our precedent establishes that the definition of "gross income" under Code § 20-108.2(C) includes items received on a one-time, non-recurring basis.

"One of the factors a trial court may consider in deciding whether to deviate is the regularity of a particular source of income." Cranwell v. Cranwell, 59 Va.App. 155, 167 (2011). Consequently, "[a]lthough the irregularity of a certain source of income for a party is irrelevant to a determination of the parties' income under Code § 20-108.2(C), such irregularity becomes relevant if the trial court subsequently considers whether to deviate from the amount of child support dictated by the statutory guidelines." Id.

"[A] trial court's interpretation of [a marital agreement] is an issue of law that we review de novo." Cranwell v. Cranwell, 59 Va. App. 155, 161 (2011) (alterations in original) (quoting Stacy v. Stacy, 53 Va. App. 38, 43 (2008) (en banc)). A. Portion of Retirement Benefit Plan Payments Due to Wife Per Settlement Agreement

All income includes irregular income. Cranwell v. Cranwell, 59 Va. App. 155, 166-67, 717 S.E.2d 797, 802 (2011). We have held, however, that trial courts need not "speculate as to what the circumstances may be in the future."

The Court further explained that "if two individuals do not share a common residence, they are not cohabiting." Cranwell v. Cranwell, 59 Va. App. 155, 162, 717 S.E.2d 797, 800 (2011). The evidence proved that wife and Craft do not share a common residence. Craft may stay at her house a few nights a month, but he has his own house.