Funds held in inherited IRAs are not retirement funds and must be included in a bankruptcy estate, the U.S. Supreme Court ruled June 12. The Court’s 9-0 ruling in Clark v. Rameker, No. 13-299 (U.S. 6/12/14), aff’d 714 F.3d 559 (7th Cir. 2013)) was definitive in drawing a distinction between inherited IRAs and retirement funds, and between inherited IRAs and other funds to which the Bankruptcy Code’s exemptions apply. The Court’s ruling ended years of ping-pong litigation in which successive courts reversed decisions by lower courts.