What is the test for intentional under-employment of a father?

[18] Moving next to the second part of the test in Drygala v. Pauli, the father was unable to prove that his intentional under-employment was due to either the reasonable needs of the child or his reasonable educational or medical needs. His efforts to justify his inability to earn income can best be described as feeble. To a large extent, he focused his blame on the mother, which was entirely irrelevant, except to the extent that it revealed to the court his hostility towards paying her any reasonable level of child support. He claimed inability to work due to medical reasons, but provided absolutely no medical evidence in support. Further, his statements during his questioning about how hard he works contradicted the medical excuse. He offered no evidence that the economic climate in his field had deteriorated in any way. He offered no evidence that he would be unable to obtain employment if he actively sought it. He offered no valid reason why he has not sought employment when his business ostensibly loses money.