Industrial Valley Bank & Trust Co. v. Rosenfield

37 Pa. D. & C.3d 621, 1985 Pa. Dist. & Cnty. Dec. LEXIS 306
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedDecember 12, 1985
Docketno. 74
StatusPublished

This text of 37 Pa. D. & C.3d 621 (Industrial Valley Bank & Trust Co. v. Rosenfield) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Industrial Valley Bank & Trust Co. v. Rosenfield, 37 Pa. D. & C.3d 621, 1985 Pa. Dist. & Cnty. Dec. LEXIS 306 (Pa. Super. Ct. 1985).

Opinion

GORDON, J.,

This action in equity was instituted by plaintiff, the Industrial Valley Bank & Trust Company (hereinafter bank) seeking to enforce a writ of execution against defendant David M. Rosenfield’s Individual Retirement Account (I.R.A.) which defendant had invested with Metropolitan Life Insurance Company (hereinafter Metropolitan). The main thrust of this case centers around the classification of I.R.A.’s for exemption from execution. Plaintiff claims that an I.R.A. is not exempt from execution by a judgment creditor because it does not classify as “certain retirement funds” under Pennsylvania’s major exemption statute, Pa.R.C.P. 3252(a). On the other hand, Rosenfield asserts that 42 Pa.C.S.' §8124(b)(viii) expressly exempts an I.R.A. from execution.

The proceedings which led up to the present action began on January 7, 1985, at which time the bank confessed judgment against Rosenfield in the Philadelphia Court of Common Pleas in the amount of $117,075.59 and commenced execution proceedings on April 19, 1985 on Rosenfield’s I.R.A. Accordingly, on May 16, 1985, the bank entered judgment against Metropolitan as garnishee in the sum of $6,771.26. Thereafter, on May 17, 1985 Rosenfield filed a claim for exemption and a hearing was scheduled for May 28, 1985, at which time de[623]*623fendant failed ,to appear and the claim was dismissed. Subsequently, the Honorable Abraham J. Gafhi vacated his order and relisted the case for a hearing on June 26, 1985, at which time this court heard oral argument on the issue. Pursuant to said hearing, on August 8, 1985, this court dismissed the writ of execution and this appeal followed.

The issue as is presented by this action is: Whether an I.R.A. under Pennsylvania laws is subject to execution by a judgment creditor?

This question is of first impression in Pennsylvania. This court, therefore, must determine if the subject matter comes within the definition of “certain retirement funds” that are classified as major exemptions in accord with Pennsylvania laws. Pa.R.C.P. 3252(a) lists the following items as major exemption from execution:

Major Exemptions Under Pennsylvania and Federal Law

1. $300 is statutory exemption.

2. Bibles, school books, sewing machines, uniforms and equipment.

3. Most wages and unemployment compensation.

4. Social security benefits.

5. Certain retirement funds and accounts. (Emphasis added.)

6. Certain veteran and armed forces benefits.
7. Certain insurance proceeds.
8. Such other exemptions as may be provided by law.

The bank asserts that the I.R.A. of Rosenfield is not protected from execution of a judgment creditor and premises its argument upon the Bankruptcy Reform Act of 1978 (11 U.S.C. §101, et seq.) and cases decided thereunder.

Plaintiff has cited several cases from the bankruptcy courts to support its position. Rosenfield pos[624]*624tures that the' provisions of the Internal Revenue Code allows him to establish an I.R.A. which is a “retirement fund” and is exempt from execution by a judgment creditor.

I.R.A.’s are éstablished pursuant to the Internal Revenue Code. Individuals are permitted to deduct amounts paid into I.R.A.’s in determining taxable income.1 Distributions from I.R.A.’s are taxed as ordinary income at the time of distribution.2 If a distribution is made before the tax payers reaches 59 and one-half years of age, there is an additional tax equal to 10 percent of the distribution.3

The intent of the Internal Revenue Code provisions for I.R.A.’s is to permit qualified individuals to enjoy certain tax advantages. Deductions are allowed in the years that contributions are made when marginal income would presumably be taxed at a relatively high rate. When distributions are subsequently made, they are taxed as earned income. At that time the taxpayer will most likely be retired and his marginal táx rate is anticipated to be relatively lower. These provisions reflect a policy encouraging retirement savings. The purpose of the law is to provide retirement security to individuals. See the Employee Retirement Income Security Act of 1974 (ERISA) P.L. 93-406, 3 U.S. Cong. & Adm. News ’74-36. p 4639

The pertinent question before this court is whether an I.R.A. is qualified as a pension plan or retirement fund to give it the protection of Pa.R.C.P. 3252(a). As noted above, the bank has cited several cases from the bankruptcy courts, to substantiate its position that I.R.A.’s are not immune from execu[625]*625tion. In reviewing those cases, the bankrupt debtors were attempting to keep their I.R.A.’s out of the reach of their creditors. Their contention was that the I.R.A.’s were pension plans and thus exempt from seizure by creditors under section 522 of the, Bankruptcy Act.4

We note that in reaching their ultimate conclusions, the bankruptcy courts relied on the existence or non-existence of state statutes to'guide them. In the case of In Re: Talbert, 15 B.R. 536 (Bkruptcy., W.D., La. (1981), the court reviewed the Louisiana exemption statute. It was said there that the claimant’s claim for exemption could only be granted if it fell under the protection of some state provision. After reviewing the statute in question (L.R.S. 20:33) the court held that the claimed I.R.A. exemption did not fall within its purview. The court went on to distinguish an exemptable pension or annuity plan from an I.R.A.

The same result was reached in the case of In Re: Mace, 4 BCD 94 (Bkrptcy.) D. Ore (1978). The court reviewed the Oregon exemption statute (ORS 23:170). The court concluded that this statute did not give the debtor cover under which he could shield himself from his creditors. See also In Re: Kitson, 431 BCD 589 (Bkrptcy. C.D. 111, (1984); In Re: Ferwerda, 424 F.2d 1131 (1970).

The state exemption statutes as interpreted by the bankruptcy courts provided the only provision for pension plan exemption from execution. While the judgment,, debtors were arguing that their I.R.A.’s, for the purpose of exemption from execution, were pension plans, the bankrúptcy courts held that I.R.A.’s were not the equivalent of a pen[626]*626sion for the purposes of exemption and denied their claims.

Some of the courts interpreted the statutes in the traditional sense that only an “employer” could establish a pension plan. They reasoned that a self-employed person could not be an “employee” in the usual sense of being employed. In Re: Ferwerda, supra. Others were concerned with the discretion that depositor could have over the I.R.A. account. In Re: Tolbert, supra.

This tribunal does not contest the holdings of the bankruptcy court, but is of the opinion that they are not controlling on the issue at hand. In accordance with those holdings, this court interprets the decisions as indicating that the only way to have an I.R.A.

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37 Pa. D. & C.3d 621, 1985 Pa. Dist. & Cnty. Dec. LEXIS 306, Counsel Stack Legal Research, https://law.counselstack.com/opinion/industrial-valley-bank-trust-co-v-rosenfield-pactcomplphilad-1985.