With no explanation, chose the best option from "A", "B", "C" or "D". the lien is so avoided, the unsecured claim that is represented by this nonre-course debt becomes an unsecured claim in the bankruptcy case. Hill, 440 B.R. at 182; In re Tran, 431 B.R. 230, 237 (Bankr. N.D.Cal.2010); 11 U.S.C. § 506(a). A creditor who asserts this unsecured claim by filing a proof of claim is further entitled to participate in the pro-rata distribution made to general unsecured creditors, if any. Hill, 440 B.R. at 183; Akram, 259 B.R. at 374. C. Propriety of Lien Avoidance in Chapter 20 Cases Some courts have concluded that a chapter 13 debtor is prohibited from confirming a chapter 13 plan which removes a lien from real property when the debtor has previously filed a chapter 7 case and received a discharge. In re Gerardin, 447 B.R. 342, 347-48 (Bankr.S.D.Fla.2011) (<HOLDING>); In re Fenn, 428 B.R. 494, 500

A: holding that a chapter 13 debtor had standing to avoid a judgment lien to the extent of her exemption amount but not the entire judgment lien
B: holding that chapter 20 debtor could not avoid lien because of ineligibility for discharge
C: holding that a socalled chapter 20 debtor may strip off a wholly unsecured junior lien
D: holding that a state tax lien was not judicial lien arising from judgment such that it could be avoided in bankruptcy by a chapter 13 debtor
B.