Yes.
As reported by Robin Miller of CBAR, disagreeing with both In re Koch, 299 B.R. 523 (Bankr. C.D. Ill. 2003) (holding that the nonrefundable general child tax credit is not exempt as a “public assistance benefit” under 735 Ill. Comp. Stat. 5/12–1001(g)(1), while the refundable additional child tax credit is exempt) and In re Hardy, 503 B.R. 722 (8th Cir. B.A.P. 2013) (holding that the refundable additional child tax credit is not an exempt “public assistance benefit” under Missouri law), the bankruptcy court held that both the refundable and the nonrefundable portions of the debtor’s federal child tax credit were exempt under 735 Ill. Comp. Stat. 5/12–1001(g)(1) as a “public assistance benefit.” Declaring that the discussion of debtors’ relative affluence inKoch and Hardy as determinative of whether an exemption could be claimed was not the most persuasive way to deal with the interplay of federal and state statutes, the court said that state legislatures should decide the parameters and limits of the exemptions they allow.
In re Vazquez, 516 B.R. 523 (Bankr. N.D. Ill., Sept. 8, 2014)
(case no. 1:13-bk-32174) (Bankruptcy Judge Jacqueline P. Cox)