With no explanation, chose the best option from "A", "B", "C" or "D". Code defines “security interest” as “a hen created by an agreement.” 11 U.S.C. § 101(51) (emphasis added). In contrast, the Code provides that the term “statutory hen” means a “hen arising solely by force of a statute on specified circumstances or conditions ... but does not include security interest or judicial hen.” 11 U.S.C. § 101(53) (emphases added). Because plaintiffs’ tax hens arose under state statute, and not from a consensual or voluntary agreement with the taxpayer defendants, we concur in the bankruptcy court’s ruling that those hens are not “security interests” for purposes of § 1322(b)(2). The foregoing interpretation of § 1322(b)(2) is supported by substantial authority from other jurisdictions. See, e.g., In re DeMaggio, 175 B.R. 144, 146-47 (Bankr. D.N.H.1994) (<HOLDING>); In re Sabec, 137 B.R. 659, 667-68 (Bankr.

A: holding that general statement of intent does not override plain language of statute
B: recognizing that legislative history is not used to create ambiguity where statutory language is clear
C: holding plain language compelled that reading
D: holding that plain language and statutory history of  1322b2 establish that noneonsensual tax hens do not fall within antimodification provision of that statute
D.