With no explanation, chose the best option from "A", "B", "C" or "D". new, fee simple interest as a result of the 2017 transfer. Thus, the Debt- or and the property interest at issue in this case are not the type that § 522(f)(1) was designed to protect. This conclusion is further buttressed by Debtor’s stated purpose for transferring the Property. As noted above, Debtor certifies that he transferred the Property to protect its equity from Sheila Zullo’s creditors. Given this intent, NJTIC questions the validity of the transfer. Without making any determination as to fraudulent intent, this Court notes that it would be contrary to the statute’s purpose—and contrary to existing case law—to permit any debtor to benefit at the expense of a legitimate creditor through a calculated, prepetition transfer of property. See Farrey, 500 U.S. at 298, 111 S.Ct. 1825 (<HOLDING>); see also Matter of Stephens, 15 B.R. at 486

A: holding that allowing lien avoidance solely under section 506d would run afoul of dewsnup 
B: holding that consumer lien avoidance powers of section 522f cannot be applied retroactively
C: holding that permitting lien avoidance in these circumstances would defraud judicial lienholders
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
C.