226 Wis. 2d 119, 593 N.W.2d 509 (WI Ct. App. 1999)
New statute limits court’s authority to modify arrearage. Where parties orally agreed to different support payment, equitable estoppel under Shulz and Harms are no longer available. Credit can only be granted under the circumstances in §767.32(1r), Stats., which is retroactive.
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