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NOTES 653 Tax Lawyer, Vol. 56, No. 3 NOTE INDIVIDUAL RETIREMENT ACCOUNTS INCIDENT TO DIVORCE ARE NOT EXCLUDABLE FROM A DEBTOR’S BANKRUPTCY ESTATE: ANDERSON V. SEAVER In Anderson v. Seaver,1 the Bankruptcy Appellate Panel for the Eighth Circuit (“Panel”) held that proceeds of an Individual Retirement Account (IRA) receiive through a divorce settlement could not be exempted from a debtor’s bankruptcy estate2 under Minnesota law.3 The Panel’s holding has two important shortcomings. First, the Panel...

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