Northern District of Illinois

In re Johnson, 480 B.R. 305 (Bankr. N.D. Ill. 2012). Mother who adopted two children with special needs, was entitled to grant of motion confirming exemption of Adoption Tax Credit in bankruptcy case because credit was a “public assistance benefit” under the Illinois Exemption Statute given the legislative history that showed the exemption was meant to defray costs of adoption for parents, particularly those with lower incomes, and to benefit child in foster care.