Appellant made a (theoretically) costly mistake in his assignments of error, because he said that the trial judge failed to consider wife’s “negative” monetary and non-monetary contributions when awarding alimony – which was not true. What he argued in his brief was the much more viable argument that the judge did not give proper weight to this factor. And no matter how well his brief may have argued this point, it is waived because Rule 5A: 20 (e) makes plain that any argument made has to have been an Assignment of Error. Husband made a number of other arguments that the court refused to consider under Rule 5A – 20, and thus it concludes wife should get an appellate fee award, and it remands to the trial court for determination of the amount. Fox v. Fox, 61 Va App 185, 734 SE 2d 662 (12/4/12).