IV for a definition of "underwater.” 3 . Lam v. Investors Thrift (In re Lam), 211 B.R. 36 (9th Cir. BAP 1997), appeal dismissed, 192 F.3d 1309 (9th Cir.1999). See infra, section IV, for a detailed discussion of Lam. 4 . Debtors’ motions were titled "Motion to Extinguish Lien of .... ” 5 . See supra, footnote 2. 6 . In re 1441 Veteran Street Co., 144 F.3d at 1291-92. 7 . A chapter 13 debtor who confirms a chapter 13 plan but fails to completely perform that plan may be eligible, on motion, to receive a "hardship” discharge, but that hardship discharge is not the "superdischarge” of chapter 13, it is the lesser discharge an eligible debtor may obtain in a chapter 7 case. 8 . Under state la see also, Hagemann v. The Chemical Mort. Co. (In re Hagemann), 86 B.R. 125 (Bankr.N.D.Ohio 1988) (<HOLDING>); accord Chandler Bank of Lyons v. Ray, 804
holding that unless security interest or lien is avoided bankruptcy discharge has little if any impact on creditors ability to proceed in rem against property securing claim holding immunity from liability is not jurisdictional holding that discharged debtor is protected only from in personam liability not in rem liability on lien given as security for mortgage loan holding that operates as a charge of debtors in personam tax liability not debtors in rem tax liability holding that reversal for a new trial on liability is appropriate only where the error complained of affects only the issues of liability