Bryan Peter Fernandes, 605 B.R. 733

Debtor received a $476 state refund (Feb 13, 2019) and a $4,686.61 federal refund (Feb 26, 2019), both direct-deposited into his checking account.
Between those deposits and the Chapter 7 petition date (Mar 11, 2019) the account had multiple deposits and withdrawals; the account balance on the petition date was $6,053.46.
Debtor claimed exemptions for the tax refunds under Miss. Code Ann. § 85-3-1(j) and (k) on Schedule C; Trustee moved to compel turnover of the account funds.
Core dispute: whether tax refund proceeds retained exempt status after being commingled with non-exempt funds in a non-exempt bank account before the petition date.
No Mississippi statute preserves exempt status for tax refunds deposited into a general account; tracing of funds was not possible from the record admitted at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pre-petition tax refunds retained exemption after being deposited and commingled in a non-exempt checking account before the petition date	Trustee: commingled funds in a non-exempt account on the petition date are property of the estate and not exempt	Debtor: refund proceeds remained exempt under Mississippi law despite deposit/commingling	Court: Held funds were non-exempt on the petition date under the snapshot rule and must be turned over ($6,053.46)

In re Brown, 807 F.3d 701 (5th Cir.) (articulating the snapshot rule for exemptions)
In re Frost, 744 F.3d 384 (5th Cir.) (exemptions determined as of the petition date)
In re Zibman, 268 F.3d 298 (5th Cir.) (state-law time-limited preservation of homestead sale proceeds for exemption)
In re Orso, 283 F.3d 686 (5th Cir.) (the petition date is the as-of date for exemptions)
In re Hawk, 871 F.3d 287 (5th Cir.) (exempt IRA funds retained status if exempt on the petition date)
Porter v. Aetna Casualty and Surety Co., 370 U.S. 159 (U.S. 1962) (veterans’ benefits retained exemption when not converted into nonexempt investments)