Joining the majority position, U.S. District Judge Walter Smith has ruled that inherited IRA accounts may be exempted as "retirement funds" under 11 U.S.C. Sec. 522(d)(12).
Hill v. Studensky, No. W-11-CA-00214 (W.D. Tex. 2/22/12), which can be found
here. (PACER registration required).