In re Reinhart, No. 09-4028, 2012 U.S. App. LEXIS 8251 (10th Cir. Apr. 24, 2012)

(debtor started Keogh retirement plan in 1992 and plan fell out of compliance with tax rules; about 10 years later, debtor filed bankruptcy under claimed funds in retirement account were exempt under Utah law even if plan not qualified for beneficial tax treatment; Utah Supreme Court, on certified question, said state law exempts funds in Keogh account if plan substantially complies with tax code; court holds that account substantially complies and funds exempt; but, contributions within one year of petition date not exempt, along with earnings on such contributed amounts).