the lien as it existed pre-bankruptcy was never challenged, the Rule 3012 motion by the FSA was sufficient to begin the process that eventually ended in the stripping down of the lien. We need not determine precisely when an adversary proceeding is required, for it is sufficient to hold that where a creditor files a proof of claim and initiates the valuation process, the debtor is not required to bring an adversary proceeding to strip down the creditor’s lien. See Halverson v. Estate of Cameron (In re Mathiason), 16 F.3d 234, 238 (8th Cir.1994) (recognizing that actions of a party may effectively transform contested motion into adversary proceeding); In re Penrod, 50 F.3d at 462-63 (allowing extinguishment of Ken without adversary proceeding); cf. Cen-Pen Corp., 58 F.3d at 92-93 (<HOLDING>). IV. The government also claims that this
holding that where no factual dispute is raised no hearing is required holding that the burden of proof is on the claimant holding that issue of whether dismissal was with or without prejudice becomes ripe only when new action is filed and issue is raised the court in the new action should decide the issue recognizing that the burden of proof is an essential element of the claim itself and that one who asserts a claim has the burden of proof that normally comes with it holding that ken survives where vakdity is at issue and no proof of claim is filed