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§ 522(d)(10)(E)

Wainer, In re

Ruling
Trustee's objection to debtors' claimed exemption in annuity proceeds overruled. (Bankr. E.D.Pa.)
Issue(s)
Exemptions; Types of Exempt Property; Benefits Akin to Future Earnings; Pensions

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Consumer opinion summary, case decided on November 16, 2021 , LexisNexis #0122-039

In re Adolphson

Ruling
Debtor's patronage account with cooperative was not exempt.
Issue(s)
Was debtor's patronage account with dairy cooperative exempt property?

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Consumer opinion summary, case decided on February 27, 2015 , LexisNexis #0315-116

Foellmi v. Ries (In re Foellmi)

Ruling
Debtor could claim exemption in interests in limited partnership distributed by employee benefit plan.
Procedural posture

A chapter 7 debtor claimed an exemption under Minn. Stat. § 550.37, subd. 24, for limited partnership units she received from her employer. The United States Bankruptcy Court for the District of Minnesota denied the claim of exemption. The debtor appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on July 31, 2012 , LexisNexis #0812-078

In re Butler

Ruling
Debtor's interest in partnership established by employer for employees was exempt.
Procedural posture

Debtor filed a petition under chapter 7 of the Bankruptcy Code and claimed that money she invested in a partnership that was available to individuals who worked for her employer was exempt from creditors' claims under 11 U.S.C.S. § 522(d)(10)(E). A trustee who was appointed to administer the debtor's bankruptcy estate filed an objection.

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Consumer opinion summary, case decided on May 29, 2012 , LexisNexis #0612-087

In re Crum

Ruling
Non-IRA account containing proceeds of two IRA accounts was not exempt.
Procedural posture

A debtor filed for relief under chapter 7 of the Bankruptcy Code. The debtor claimed exemptions in three bank accounts totalling $254,902, $38,080, and $79 respectively and a claimed exemption in $11,000 conveyed to a third party pre-petition. A creditor and a chapter 7 trustee objected to the claimed exemptions.

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Consumer opinion summary, case decided on February 20, 2009 , LexisNexis #0409-005

In re Krebs

Ruling
Debtor's IRA could potentially be exempted although withdrawals could not yet be made without penalty.
Procedural posture

Appellee chapter 7 trustee filed an objection in bankruptcy court to appellant debtor's request for exemption of an individual retirement account (IRA) under 11 U.S.C.S. § 522(d)(10)(E). The bankruptcy court sustained the objection, and the District Court for the Western District of Pennsylvania affirmed. The debtor appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on May 19, 2008 , LexisNexis #0608-061

Walsh v. Benson (In re Benson)

Ruling
IRA exemption disallowed to the extent funds were not reasonably necessary to support debtor and spouse.
Procedural posture

The matter was before the court following remand by the district court, which concluded that the court erred as a matter of law in sustaining the trustee's objections to exemptions respondent debtors had taken in portions of their respective individual retirement accounts (IRAs) in accordance with 11 U.S.C. § 522(d)(10)(E).

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opinion summary, case decided on March 26, 2007 , LexisNexis #0507-057

Walsh v. McMurry

Ruling
Case remanded to bankruptcy court for determination as to whether IRA was reasonably necessary to support debtor and family and therefore partially exempt.
Procedural posture

Appellee bankruptcy trustee objected when appellant chapter 7 debtor claimed an exemption from the bankruptcy estate for his entire individual retirement account ("IRA"). The debtor appealed after the bankruptcy court sustained the objection and ruled that a portion of his IRA was not exempt under 11 U.S.C. § 522(d)(10)(E).

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opinion summary, case decided on August 18, 2006 , LexisNexis #0906-084

Walsh v. Benson

Ruling
Bankruptcy court erred in concluding that IRA was not eligible for exemption.
Procedural posture

Appellant debtor appealed the opinion and order of the bankruptcy court which held that the debtor's Individual Retirement Account ("IRA") was neither excluded from the bankruptcy estate under 11 U.S.C. § 541(c)(2) nor exempt under 11 U.S.C. § 522(d)(10)(E). Appellee trustee opposed the appeal.

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opinion summary, case decided on August 18, 2006 , LexisNexis #0906-083