(Id. at 89.)[11] We begin by noting that courts in other jurisdictions have held – when a divorce settlement agreement or a divorce decree has given a percentage of Spouse B's military retirement to Spouse A – that if Spouse B thereafter unilaterally forfeits military retirement by accepting VSI payments, Spouse A is entitled to receive the expected monies from Spouse B's VSI payments in lieu of receiving those monies from retirement benefits that no longer exist.See , e.g. , Kelson v. Kelson , 675 So.2d 1370, 1372 (Fla. 1996), reh'g denied ; Fisher v. Fisher , 319 S.C. 500, 505-506, 462 S.E.2d 303 (S.C. Ct. App. 1995), reh'g denied ; Marriage of Babauta , 66 Cal.App.4th 784, 78 Cal. Rptr. 2d 281, 283 (Cal. Ct. App. 1998) ; Marriage of Menard , 180 Or.App. 181, 42 P.3d 359, 364 (2002). Susan, in essence, wants us to hold that the inverse is also true – that her entitlement to a portion of Michael's VSI payments under the Agreement converted into an entitlement to a portion of Michael's military pension when Michael became eligible for the pension instead of VSI.

See Fisher v. Fisher, 319 S.C. 500, 504, 462 S.E.2d 303, 305 (1995) ("husband's early discharge under the VSI program is analogous to an early retirement . . . [because] any rights the husband now possesses to receive early discharge incentive payments are due to the time he spent in the military and accrued during his marriage to the wife"); Marsh v. Marsh, 973 P.2d 988, 991 (Ut.App. 1999) (SSB determined to be "analogous to retirement pay"); In re Heupel, 936 P.2d 561, 569 (Colo. 1997) (VSI and SSB "are meant to compensate for the loss of the right to receive retired pay in the future whether characterized as a buyout, an advance, or deferred compensation for services already rendered"); In re Babauta, 66 Cal.App.4th 784, 78 Cal.Rptr.2d 281 (1998) (VSI and SSB benefits determined to be community property); Marsh v. Wallace, 924 S.W.2d 423, 426 (Tex.App. 1996) (SSB "is not compensation for lost future wages but instead compensation for lost retirement pay earned in the past that [husband] voluntarily gave up receiving in the future"); Pavatt v. Pavatt, 920 P.2d 1074, 1076 (Okla.Civ.App. 1996) ("SSB payment is to be treated as a retirement plan asset"); Kulscar v. Kulscar, 896 P.2d 1206 (Okla.App. 1995) (SSB payments are in lieu of retirement benefits); In re McElroy, 905 P.2d 1016 (Colo.App. 1995) (SSB's are marital property). The analogy in Blair v. Blair, likening incentive payments to early retirement, is typical of the rationale reached by the majority of the cases our research has revealed:

Although White cites several cases from other states purporting to support his argument, we note that each of the cases cited by White address the issue of veterans disability payments being included in marital property for purposes of property division. See West v. West, 736 S.W.2d 31 (Ky.App. 1987); In re Marriage of Costo, 203 Cal. Rep. 85 (1984), holding questioned by In re Marriage of Babauta, 66 Cal.App.4th 784 (1998); Ramsey v. Ramsey, 474 S.W.2d 939 (Tx.App. 1971); Rickman v. Rickman, 605 P.2d 909 (Ariz.App. 1980). The issue in this case, however, is whether veterans disability payments may be included in gross income for calculating child support.