Daniels v. Agin, 736 F.3d 70

Daniels operated a profit-sharing plan and served as trustee, administrator, and sole participant; plan assets included two IRAs funded from plan assets.
Bankruptcy court ruled the plan was not exempt due to noncompliance with tax laws, making plan assets and the two IRAs part of the estate.
Daniels failed to disclose the two IRAs on Schedule B/C, treating all funds as held by the plan.
The IRS audited the plan (2006) and identified a prohibited loan; audit did not disqualify the plan, but noted issues.
During bankruptcy proceedings, Daniels gave inconsistent or incomplete explanations about the IRAs at creditors’ meetings and in filings.
Trustee amended turnover to include the IRAs; bankruptcy court held the IRAs were nonexempt and/or concealed, supporting revocation of discharge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the Plan assets exempt under § 522(b)(3)(C)?	Daniels argues audit creates favorable determination signaling exemption.	Bankruptcy court found substantial noncompliance and prohibited transactions negate exemption.	Plan assets not exempt; IRAs derived from plan also nonexempt.
Did Daniels’ conduct constitute concealment of estate assets sufficient to deny exemption for the IRAs?	Daniels relied on counsel and disclosed total amounts; IRAs were disclosed later.	Concealment was intentional/reckless and spanned proceedings; material information was omitted.	Yes; intentional concealment or reckless indifference barred exemption.
Was the revocation of Daniels’ discharge proper based on concealment?	Revocation grounded in concealment and bad faith; collateral estoppel considerations apply.	Defense argued insufficient to revoke discharge and that new evidence justified relief.	Revocation upheld based on reckless disregard for truth and concealment.
Did Rule 60(b) relief permit reconsideration or relief from judgment on new evidence or excusable neglect?	New evidence and attorney health issues justify relief.	Evidence was available earlier; neglect was not excusable; no abuse of discretion.	Rule 60(b) relief denied.

In re Moultonborough Hotel Grp., LLC, 726 F.3d 1 (1st Cir. 2013) (apply summary-judgment standards in bankruptcy appeals)
In re Varrasso, 37 F.3d 760 (1st Cir. 1994) (summary judgment on discharge when asset omission exists but intent disputed)
In re Marrama, 445 F.3d 518 (1st Cir. 2006) (transfers indicating fraud support denial of discharge)
In re Wood, 291 B.R. 219 (1st Cir. BAP 2003) (concealment of estate property and bad faith considerations)
In re Plunk, 481 F.3d 302 (5th Cir. 2007) (IRS audit not necessarily a favorable determination; independent analysis allowed)
In re Tully, 818 F.2d 106 (1st Cir. 1987) (reckless indifference treated as fraud for discharge-denial purposes)
In re Daniels, 452 B.R. 335 (Bankr. D. Mass. 2011) (bankruptcy court findings on nonexemption and concealment underpin appellate rulings)
In re Villani, 478 B.R. 51 (1st Cir. BAP 2012) (reckless disregard as a standard for doctrinal relief)