With no explanation, chose the best option from "A", "B", "C" or "D". that may be precisely what the Legislature intended.” PPG Indus., Inc. v. JMB/Houston Ctrs. Partners Ltd. P’ship, 146 S.W.3d 79, 84 (Tex.2004). In the absence of any comparable provision under Chapter 156, I read Section 157.167 as a deliberate choice on the part of the legislature to restrict the taxation of attorney’s fees as child support to suits involving the enforcement of a prior order. This interpretation corresponds with the logical notion that the legislature appreciated the practical disparity between modification and enforcement suits; a judgment against a parent who is presently behind in child support will almost certainly require more compelling means of enforcement than a judgment against a parent with no proven history of arrears. See Moers, 104 S.W.3d at 611-12 (<HOLDING>); see also Markowsky v. Newman, 134 Tex. 440,

A: holding that a judgment for attorneys fees may be rendered in the nature of child support regardless of whether the underlying action is one of enforcement or modification
B: recognizing the serious consequences that stem from taxing attorneys fees as child support and observing the effort to limit their expansion beyond the enforcement context where the threat of contempt is most justified
C: recognizing that under a limited exception attorneys fees may be recovered by a party who gains enforcement of a previous support order even when no contempt is ordered
D: holding that attorneys fees and costs may not be awarded as child support when they are incurred in a suit to modify the parentchild relationship that does not involve the enforcement of a child support obligation
B.