In Cohen v. Garcia-Morales, No. 24-1384 (10th Cir. Aug. 19, 2025), the Tenth Circuit addressed whether a Chapter 7 debtor’s federal tax refund, traceable to a refundable child tax credit, must be turned over to the bankruptcy trustee. Affirming both the bankruptcy and district courts, the panel held that the refund was wholly exempt under Colorado law.
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