With no explanation, chose the best option from "A", "B", "C" or "D". has an interest” under the language of § 506(a), and therefore no portion of the lien may be voided under § 506(d); 2) allowing such lien avoidance inequitably gives debtors more in Chapter 7 than in reorganization chapters; and 3) allowing such lien avoidance under § 506(d) would render redundant 11 U.S.C. § 722, which allows for redemption of personal property but not real property. Id. at 589-90. Other courts adopting the minority view include In re Lange, 120 B.R. 132, 135 (9th Cir.BAP 1990) (listing above reasons and adopting reasoning of Dewsnup); In re Mammoser, 115 B.R. 758, 759-60 (Bankr.W.D.N.Y.1990) (rejecting reasoning of Gaglia and holding that § 506(d) is not an avoiding power, but rather an implementing provision); In re Shrum, 98 B.R. 995, 1002 (Bankr.W.D.Okla.1989) (<HOLDING>); In re Maitland, 61 B.R. 130, 132-35

A: holding that because property was no longer property of the estate the court could not order turnover
B: holding that the debtor could retain exempt property because it was not property of the estate
C: holding that property not subject to sequestration is not therefore exempt
D: holding that abandoned or exempt property is no longer part of the estate and therefore  506d is not available to void the undersecured portion of a lien
D.