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
holding that chapter 20 debtor could not avoid lien because of ineligibility for discharge 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 holding that a socalled chapter 20 debtor may strip off a wholly unsecured junior lien 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 holding state courts authority under iowa code section 59821 not the lien created there under prevented debtor from claiming the iowa homestead exemption and therefore the debtor could not avoid the lien because the lien did not impair an exemption to which the debtor would have been entitled but for the lien