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.

A judge sitting in a proper venue may transfer venue to a district that was improper originally.

An election for having a tax refund applied to the following year’s taxes can result in the loss of discharge.

Sixth Circuit judges wrote 17 pages of dicta to muse on whether the ‘person aggrieved’ test for appellate standing died with the adoption of the Bankruptcy Code but remains good law under the ‘zone-of-interests’ test.

Bound by Dow Corning, which permitted nondebtor releases, the Sixth Circuit had to explain why the same releases are not permissible in equity receiverships.

If tax foreclosures violate the Takings Clause, it stands to reason that they are also fraudulent transfers.

Waiting four years to raise discharge as a defense does not invoke equitable estoppel or laches.

A creditor can’t be compelled to arbitrate the validity of a claim before the bankruptcy court decides whether the involuntary petitioner’s claim is subject to a bona fide dispute.

Affirming the bankruptcy court, the Sixth Circuit BAP won’t exempt proceeds from the prepetition sale of a home, even though the proceeds were identifiable and in escrow.

In fee allowances, considering ‘results obtained’ survived the 1994 amendments to Section 330(a).