with whom CARPENETI, Justice, joins, dissenting in part.
The court reasons that the superior court erred in assuming that appellant Shepherd would pay no income taxes.1 Because such an error could affect the child support award,2 the court remands for determination of appellant's income tax liability.3
I respectfully dissent from the part of the court's opinion that remands for that determination. Appellant's lawyers have not argued any such error on appeal and the pro se appellee has not addressed the topic. The court concludes that appellant Shepherd adequately raised the income tax question on appeal,4 but in my view, she did not raise the issue at all, either explicitly or implicitly. We should therefore not consider the income tax liability topic, much less grant relief to appellant on this unpreserved issue.
It may seem hypertechnical to require an appellant to argue an issue explicitly. After all, the appellant here probably raised the issue in the superior court, and this court apparently considers the issue to be so clear that its merits can be resolved with only four lines of discussion5 and without benefit of appellate briefing. But there are good reasons for requiring appellants to argue an issue explicitly, or at least implicitly.
*651Our appellate rules specify how litigants must present issues and we have applied those standards in treating as waived issues that were not adequately briefed. Thus, Appellate Rule 212(c), labeled "Substantive Requirements," specifies that the appellant's brief "shall contain," among other items, a statement of issues presented for review, a statement of the case describing the procedural history and relevant facts, an argument section, and a "short" conclusion stating the "precise relief sought." Appellate Rule 212(c)(1)(I) provides that the argument seetion "shall contain the contentions of the appellant with respect to the issues presented, and the reasons therefor, with citations to the authorities, statutes, and parts of the record relied on." (Emphasis added.) We do not treat the argument requirement lightly. We have held that "[where a point is not given more than a cursory statement in the argument portion of a brief, the point will not be considered on appeal."6 Even pro se litigants must adhere to this standard even though we tend to be more expansive in interpreting their arguments.7
We adopted Rule 212 not to satisfy an esthetic interest in the cosmetic appearance of briefs, but to make sure that the issues we decide are truly in controversy, that we do not overlook issues the parties have raised, and that we have the benefit of the parties' thoughts about the facts and law bearing on issues we are deciding. Some elemental rig- or in describing the issues for decision also helps with the doctrines of law of the case and res judicata.
Due process is the ultimate foundation for the preservation requirement. Ruling against an appellee on an issue the appellant has not raised deprives the appellee of notice and an opportunity to be heard. Doing so can be especially prejudicial to pro se appel-lees, who lose both the opportunity to decide whether to hire counsel to address the (un-raised) issue and the opportunity to address the issue themselves.
There are various reasons why an appellant might not brief a particular issue. An appellant might decide to focus on particularly compelling contentions, and to ignore others. The primary, if not only, theme of Shepherd's appeal is that it was error to impute rental income to Shepherd. Appellant's Brief at 1, 18-14, 15, 16, 21, 22, 28, 24, 25. Counsel could have reasoned that this was a compelling theme, given undisputed evidence that Shepherd had been awarded only one rental property, that she sold in 2008. And evidence she sold only it because appellee failed to pay child support supported her assertion that she did not unreasonably or voluntarily forgo rental income, thus making imputation inappropriate. Appellant's Brief at 19-20, 28-24. There is good reason to think appellant's counsel chose not to argue the tax issue.8 An appellant might also choose to avoid an issue in order to limit the appellee's responsive arguments and minimize discussion of unflattering evidence or legal propositions, or to limit the issues to be litigated on remand.
Of course, a party might not raise an issue through simple oversight. But even if an appellant's lawyer is negligent in failing to brief a meritorious issue or a pro se appellant fails to discuss an issue, we regard it as unraised.9 It does not matter why the issue *652is not raised; we do not decide issues not raised by the parties.10
This is a particularly unworthy case for considering an unraised issue and using it to grant relief to appellant. Two lawyers cosigned Shepherd's substantial opening and reply briefs, and her oral argument exceeded the usual time allotted. Haralovich, by comparison, filed only an eight-page pro se brief, much of which discusses matters of little relevance to the issues on appeal. He argued for only nine of his allotted fifteen minutes. Here Shepherd had the burden of going forward on appeal and demonstrating both legal error and prejudice. If, as I think, she did not raise the issue, the pro se appellee is being treated unjustly.
Do Shepherd's briefs raise the issue? No. Not explicitly. Not implicitly. And certainly not adequately.
The issue and argument parts of Shepherd's two briefs do not list, describe, or discuss any error in calculating the income tax deduction. It would therefore seem that prolonged review of the appellant's briefs is not needed to confirm that Shepherd has not asked us to reverse on the theory the superi- or court miscaleulated the income tax deduction in awarding child support. If Shepherd were asking us to do so, one would expect the argument part of her brief to clearly and directly assert that the superior court erred by failing to deduct Shepherd's tax liability and by assuming there was zero tax liability, and that reversal is therefore required. This argument can be easily made. It is factually and legally simple. Although she made no such argument on appeal she raised the issue in the superior court. The argument there could have been clearer, but she asserted that it was error to assume Shepherd had no income tax liability. This confirms that her lawyers, who co-signed her appellate briefs and also represented her in the superior court, knew how to raise the issue when they wanted to.
The court's opinion reviews Shepherd's opening brief at some length and concludes that the issue was raised, at least implicitly.11 A casual reader unfamiliar with Shepherd's briefs and her actual arguments might assume from the court's description of her opening brief that Shepherd actually argued the issue. Only a reader familiar with that brief would know what part of the brief contains the passages quoted or described by the court.
Considered part-by-part, appellant's opening brief does not brief the remand issue. All of the direct references to the "issue" are found in, and only in, the part of the opening brief discussing the transactional and procedural facts.12
Thus, the table of contents of the opening brief lists the argument section's main topic headings as follows: "The trial court erred by imputing any income to Ms. Shepherd, who is neither unemployed nor underemployed. ... The record does not support the trial court's calculation of imputed income." Appellant's Brief at ii. Neither heading mentions taxes; both headings refer to imputation of income.
Part V of the brief lists the two issues presented for review as follows:
1. Did the trial court err by imputing income to appellant?
2. If the trial court did not err in imputing income to appellant, did the trial court err in determining the amount of income to impute to appellant?
Appellant's Brief at 1. Both issues focus on the imputation of income. The first asks *653whether it was error to impute income to Shepherd; the second asks whether the court erroneously determined the amount of imputed income. Neither issue as set out mentions taxes or tax errors. No standalone computational issue is listed; the computational issue listed by Shepherd arises only if the superior court imputed income to Shepherd.
The court correctly notes that Part VI of the brief, setting out the "statement of the case," does discuss the superior court's rulings on the income tax deduction and what the superior court assumed about Shepherd's annual income taxes.13 That part is fourteen pages long. It also discusses many other transactional and procedural facts. Appellant's Brief at 1-14. Some of those facts do not directly bear on any appellate issue, and many relate to the property division that awarded the rental property to Shepherd, her sale of that property, and Haralovieh's alleged noncompliance with his child support obligations. Shepherd's fact statement discusses at length the orders and reconsideration motions that culminated in the September 2004 order. Appellant's Brief at 1-14. It consequently describes a variety of superi- or court issues and rulings that are not at issue on appeal.
Part VIII is the briefs argument part. It contains three sections. The first section discusses "applicable case law." This section discusses only the legal standard for deciding whether to impute income. Appellant's Brief at 15-17. It does not discuss how any imputed amount should be calculated. It focuses on demonstrating that income may be imputed only if a parent is voluntarily and unreasonably unemployed or underemployed. Appellant's Brief at 17.
The second and third sections of appellant's argument part both address imputed rental income. Both presuppose that the superior court imputed rental income to Shepherd. Both therefore state the issues in even more limited fashion than the two issues described in Part V, which lists the issues presented for review.
Thus, the second argument section argues that it was error to impute rental income to Shepherd for property she no longer owns. Appellant's Brief at 21. Nothing in that section discusses income tax liability; it largely focuses on her contention that she acted reasonably and involuntarily in 2003 when she sold the only rental property she owned, and that the standard for imputing income was therefore not met.14 Appellant's Brief at 19-21. There is no basis in this argument section for granting her any appellate relief if, as the entire court agrees, the superior court did not in fact impute any rental income to Shepherd.15
The third argument section argues that the record does not support imputing to Shepherd net rental income of $21,288. Appellant's Brief at 21. It also contains ancillary arguments, all relating to imputation of rental income. None of those arguments asserts that the superior court erred in basing the income calculation on the one-year experience of zero tax liability. Appellant's Brief at 22-28. None challenges "the correctness of the trial court's assumption in calculating child support that there would be no federal income tax liability," as this court describes the issue before deciding whether it was "raised and argued sufficiently so as to be properly before us on appeal." 16 Critical to her argument that there was a caleulational error is Shepherd's contention that the superior court imputed a substantial amount of rental income to her. But all members of this court agree that there was no imputation *654of rental income.17 We thus unanimously reject the root of her argument. Her claim of calculational error, as argued, withers away.
Part IV.B of the court's opinion concludes that Shepherd raised and sufficiently argued the issue of income tax liability.18 I disagree. Surely Haralovich will too, when he learns to his surprise that the only issue on which the court remands is one that Shepherd has not argued on appeal and which Haralovich therefore had no reason to think he should address either.
I do not think Shepherd has preserved the issue merely by unfavorably characterizing in the facts section of her brief the superior court's decision not to give her credit for any income tax deductions.19
I also do not think that the portion of Shepherd's argument section quoted at length on page 650 of the court's opinion refers, expressly or implicitly, to Shepherd's income tax liability. Shepherd argues in that passage only that if any rental income is to be imputed to her, it should be only the average of her rental income over two years, including a year in which she earned no rental income.20 Appellant's Brief at 25. This reading of the argument is supported by Shepherd's reply brief, which states that "the matter now properly before this Court [is] [dlid the trial court erroneously impute nonexistent rental income from long-sold property to appellant?" Reply Brief at 1. Her reply brief later reiterates the dispute as she sees it: "the issue properly before this court [is] imputation of income to Ms. Shepherd from real property previously sold." Reply Brief at 8.
The court reads passages in Shepherd's brief as discussing and raising the issue, at least implicitly.21 But all of the passages discussed by the court's opinion on pages 649-50 are found only in the fact portion, not the argument portion, of appellant's brief. The passage quoted in the opinion at pages 649-50 says nothing of an alleged error in assuming zero tax liability. That passage speaks of "0" rental income, not of an erroneous assumption there was "0" tax.22
The issue perceived by the court is not "implicit" nor can it be characterized as having received even "minimal treatment."23 If the issue had been raised, one would expect Shepherd's lawyers to have cited some authority to demonstrate the error, presumably the same Civil Rule the court cites in confirming that income tax is to be deducted from gross income.24 But the passage of the brief quoted at page 650 of the opinion says nothing of a failure to deduct taxes, cites no rule or case discussing a deduction for taxes, and only refers to the tax returns to demonstrate that rental income dropped to zero in 2008. Appellant's Brief at 25. This argument is made to support Shepherd's claim the rental income should be averaged, not that tax payments should be deducted. Appellant's Brief at 25.25
*655The topic did come up briefly at oral argument, but only because a member of this court asked Shepherd's counsel if the September order was in error because the superior court assumed that Shepherd's normal federal income tax liability was zero. Not surprisingly, counsel agreed, recognizing a slow pitch when he saw one, but nothing in appellant's briefs raised that question. And if a member of the court had not asked that question, the topic would not have been mentioned at argument. Parties may not raise new issues at oral argument.26 That the court sua sponte raised the topic at argument does not excuse Shepherd's failure to preserve the issue. Haralovich, representing himself, had no adequate warning that he should be prepared to discuss a topic not mentioned in the briefs.
Finally, even if Shepherd's opening brief could be charitably read to have mentioned the issue, it was mentioned so indirectly and obscurely that we should hold the discussion was too cursory to have preserved the issue.
We should therefore affirm every aspect of the superior court's final order denying reconsideration. I join in the court's opinion to the extent it affirms the superior court's order denying reconsideration.
. Majority at 649, 650.
. Alaska R. Civ. P. 90.3(a)(1)(A)(i) (providing that income taxes are deductible from gross income).
. Majority at 650.
. Majority at 649-50.
. Majority at 650.
. Petersen v. Mut. Life Ins. Co. of N.Y., 803 P.2d 406, 410 (Alaska 1990) (citations omitted).
. Peterson v. Ek, 93 P.3d 458, 464 n. 9 (Alaska 2004) (stating that "[wle judge a pro se litigant's performance by a less demanding standard"); Gates v. City of Tenakee Springs, 822 P.2d 455, 460 (Alaska 1991) (treating as abandoned claims of pro se litigant raised below but only cursorily or not at all on appeal).
. Shepherd's statement of points on appeal, filed when she commenced her appeal, included this appellate contention: "2. The trial court erred in failing to include mandatory deductions from gross income which appellant is entitled to receive pursuant to Alaska R. Civ. P. 90.3." Had this point been discussed in these terms in appellant's arguments, there is no question she would have preserved it. But because the other two points listed on her statement of points on appeal correspond exactly to the two arguments she does raise in Part VIII of her brief, it appears she intentionally chose not to brief this issue. Comparing the texi of the point with the text of her arguments also strongly suggests intentional waiver. See note 25 below.
. Cf. State v. O'Neill Investigations, Inc., 609 P.2d 520, 528 (Alaska 1980) ("When, in the argument portion of a brief, a major point has been given no more than cursory statement, we will not *652consider it further. Failure to argue a point constitutes an abandonment of it.").
. Id.
. Majority at 649-50. The court refers only to appellant's opening brief. Nothing in appellant's reply brief can be read to raise the issue, although the reply brief does confirm how limited the appellate issues are. Thus, it asserts that "Many of appellee's assertions are simply not relevant to the matter properly before this Court: Did the trial court erroneously impute non-existent rental income from long-sold property to appellant?" Reply Brief at 1.
. I use the word "issue" advisedly, without implying that the tax question is indeed an "appellate issue." The tax question was an issue in the superior court. It is an issue before this court only because this court says it is, not because the appellant says it is.
. This is the part that, per Appellate Rule 212(c)(1)(G), "shall provide a brief description of the case and a concise statement of the course of proceedings in, and the decision of, the trial court. Appellant shall state the facts relevant to each issue, with references to the record as required by paragraph (c)(8), in this section or in the appropriate argument sections."
. To impute employment income, a court must first find voluntary and unreasonable unemployment or underemployment. Majority at 647 (citing Alaska Civil Rule 90.3(a)(4)). Shepherd relies on the standard for imputing employment income, but she is actually contending that the superior court imputed rental, not employment, income to her. Appellant's Brief at 17, 19-21.
. Majority at 648-49.
. Majority at 649.
. Majority at 649-50.
. Majority at 649-50.
. The distinction between the fact and argument sections of the brief may seem, at first glance, to be unduly harsh. It is not, for two reasons. First, Alaska Appellate Rule 212(c)(1)(I) and our case law both explicitly require that issues be preserved in the argument portion of the brief. Second, if we permit parties to treat negative characterizations of the superior court's decision as if they were legal arguments, we allow them to unfairly surprise their adversaries. Following this case, parties will be required to carefully parse the facts for any lurking legal issues, even if their opponent is represented by legal counsel. Moreover, parties often include a thorough discussion of the procedural history of a case, partly because our rules seem to encourage it, and perhaps also to give some indication whether any alleged error was harmless or prejudicial. Treating this history as argument, at least for represented appellants, can only lead to surprise and confusion.
. Majority at 649-50.
. Majority at 649-50.
. Compare Majority at 650 with Shepherd's quoted passage.
. Majority at 649-50.
. Majority at 650 (citing Alaska Civil Rule 90.3(a)(1)(A)@)).
. Comparing appellant's brief with the statement of points appellant filed when she commenced her appeal, see footnote 8, above, confirms that she has not argued the issue, even *655implicitly. The relevant words in her second point on appeal are "mandatory deductions," "gross income," and Civil Rule "90.3." "Mandatory," "deductions," "gross income," and "90.3" appear nowhere in the table of contents {and thus the argument headings), the list of issues, the standard of review, or the conclusion sections of appellant's brief. The words "mandatory," "deductions," and "gross income" appear nowhere in the three parts of appellant's argument section of her brief. And the references to Rule 90.3 in the argument section are never offered to support any contention that income taxes must be deducted from gross income, or that the superior court erred in calculating income tax liability or deductions due for income tax liability. The statement of points on appeal therefore implies that Shepherd's attorneys chose to waive the argument on appeal.
. See Petersen v. Mut. Life Ins. Co. of N.Y., 803 P.2d 406, 411 (Alaska 1990) (holding that when appellant's brief does not raise an argument, issue is waived).