Although not held in an IRA, a refund by the IRS of a withdrawal penalty was exempt because state law permits tracing proceeds of exemptions, Judge Opperman says.

Are there two tests for the existence of a claim, one test for claims against the debtor and another test for claims by the debtor?

Abstention can’t be used to peel off some claims from an adversary proceeding, the BAP says.

A trust designed to defeat the claims of creditors can sometimes hold up in bankruptcy.