Taylor v. United States, 212 F.3d 395 (8^th Cir. 2000)-This appeal addressed the question of how a bankruptcy court should treat an ERISA plan in the calculation of income in bankruptcy.  The Taylors appealed the bankruptcy court's inclusion of the income from Gerald Taylor's ERISA-qualified pension in its calculation of the Taylors' disposable income.  The Taylors argued that according to Patterson v. Shumate, 504 U.S. 753 (1992), ERISA's anti-alienation provisions, see 29 U.S.C. § 1056(d)(1), exempt the pension plan from the disposable income calculation.

            This court disagreed with the Taylor's reading of Patterson.  The fact that a pension is exempt from the reach of creditors does not preclude a bankruptcy court from finding that the pension is also disposable income for purposes of Chapter 13. Federal anti-alienation provisions are thus irrelevant in a Chapter 13 context.