Chilton v. Moser, 674 F.3d 486

The Chiltons inherited Heil's IRA worth $170,000 and opened an inherited IRA.
They filed for bankruptcy under Chapter 7, then converted to Chapter 13.
The trustee objected to exempting the inherited IRA under 11 U.S.C. § 522(d)(12).
Bankruptcy court sustained the trustee's objection; district court reversed in the Chiltons' favor.
The Fifth Circuit affirmed, holding inherited IRAs are exempt under § 522(d)(12).
The key issue is whether inherited IRAs qualify as retirement funds in exempt accounts under the IRC.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are inherited IRAs 'retirement funds' under § 522(d)(12)?	Moser argues inherited IRAs are not retirement funds.	Chiltons contend inherited IRAs are retirement funds under the statute.	Yes; inherited IRAs are retirement funds.
Are inherited IRAs 'in a fund or account that is exempt from taxation' under § 522(d)(12)?	Moser argues inherited IRAs are not tax-exempt under the relevant IRC provisions after transfer.	Chiltons assert inherited IRAs are tax-exempt under IRC provisions applicable to IRAs.	Yes; inherited IRAs are in an exempt account under IRC § 408 after transfer.
Which IRC provision renders inherited IRAs tax-exempt post-transfer for § 522(d)(12) purposes?	Moser argues no applicable provision post-transfer.	Chiltons rely on § 408(e) to render inherited IRAs tax-exempt.	Post-transfer exemption under § 408(e) applies.

Rousey v. Jacoway, 544 U.S. 320 (2005) (exemption framework for bankruptcy exemptions and burden on objecting party)
In re Nessa, 426 B.R. 312 (8th Cir. BAP 2010) (retirement funds can include inherited IRAs under § 522(d)(12))
In re Kuchta, 434 B.R. 843 (Bankr. N.D. Ohio 2010) (analysis of retirement funds and inheritance context under § 522(d)(12))
In re Tabor, 433 B.R. 469 (Bankr. M.D. Pa. 2010) (inherited IRAs regarded as retirement funds for exemption purposes)
In re Thiem, 443 B.R. 832 (Bankr. D. Ariz. 2011) (inherited IRAs treated as retirement funds under § 522(d)(12))