Adkisson describes the case of Maryland resident Joseph K. Rensin and his established “Joren Trust,” which “illustrates the advantages of planning in a state such as Florida that exempts annuity payments either wholly or in substantial part from enforcement of a judgment, which can then provide the debtor with some means to live on while creditors are hovering.” Additionally, Adkisson states that the opinion also demonstrates the difference between an annuitized annuity (which is protected from creditors) and a not-yet-annuitized deffered annuity (for which no exemption may be available and which may be deemed to be part of the debtor’s bankruptcy estate).
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