John & Debra Schmidthuber v. Richard Myers, Trustee (In re Schmidthuber), Ch. 7, BK81-384, A81-574
Reported at 18 B.R. 129. Debtors may exempt a tax refund not disclosed in their original schedules because the late schedule amendment didn't interfere with estate administration & because exemptions should benefit debtors to the fullest extent