Is it time to use individual retirement annuities rather than IRA when beneficiaries have creditor problems? In this criticized court case, the Second District Court of Appeals for Florida found that a beneficiary who opted to transfer his father's IRA into an "inherited IRA," meaning the account goes out of the name of the decedent into the name of the decedent for the benefit of the beneficiary so that distributions can be spread over the beneficiary's life, would not be allowed protection from creditors provided by Florida Statutes section 222.21. Robertson v. Deeb, 16 So. 3d 936 (Fla. 2d DCA 2009)