disability insurance payments, even if those payments are exempt property under 11 U.S.C. section 522. The issue before us, then, is whether Kan-cilia's exemption under section 522 for his disability payments protects those payments from garnishment by creditors holding non-dischargeable debt under section 528. Seetion 522(c) states that exempt property "is not liable during or after the case for any debt of the debtor that arose ... before the commencement of the case" (emphasis added). It goes on to provide four exceptions in which creditors with nondischargeable debt may reach exempt property: (1) debt for taxes or domestic support obligations; (2) debt secured by an unavoidable lien or tax lien; (8) debt caused by a fiduciary's fraud, or debt caused by willful and mal 1994) (<HOLDING>); In re Ewiak, 75 BR. 211, 212
holding that because nondischargeable debt based on fraud was not one of the four enumerated exceptions to exempt property the exempt property was not liable for the creditors surviving claim holding that property not subject to sequestration is not therefore exempt holding that trial court erred by granting surviving spouse fee simple title to estates exempt property recognizing that exempt property ceases to be property of the estate holding that the debtor could retain exempt property because it was not property of the estate