Tax Refunds and Tenancy by the Entireties

A few days ago another court upheld the claim of exemption as tenancy by the entireties in a tax refund.  In re Newcomb,  2012 Bankr Lexis 5654 (Bankr. M.D.  FL  Dec 4, 2012).  The court did discuss the conflicting authority amongst Florida bankruptcy judges.  The court reasoned that there was a rebuttable presumption  in favor of finding that personal property owned by husband and wife was held as tenancy by the entireties.