In re Howard (04-10131)
Debtor’s early withdrawals from his IRA, which were used to pay bills, were not the type of "prohibited transactions" that would have caused the entire account to lose its status as an IRA under the Internal Revenue Code. Thus, any money in the IRA at the time Debtor filed his bankruptcy petition could be exempted pursuant to O.C.G.A. § 44-13-100(a)(2.1)(D).