on procedural grounds without reaching issue of applicability of automatic stay); In re Le Peck Constr. Corp., 14 B.R. 195 (Bankr.E.D.N.Y.1981) (bankruptcy court held that the automatic stay of a Chapter 11 debtor which possessed a post-petition mechanic’s lien for postpetition work it performed on a building did not preclude a senior lien holder’s foreclosure on the building); In re Holiday Lodge, Inc., 300 F.2d 516 (7th Cir.1962) (in a case under the Bankruptcy Act, Seventh Circuit held that the bankruptcy court could not restrain a senior secured creditor from foreclosing a mortgage on real property that was subject to a lease held by the debtor because the debtor had no interest in the real property). But see In re Capital Mortgage & Loan, Inc., 35 B.R. 967 (Bankr.E.D.Ca.1983) (<HOLDING>); Cardinal Industries, Inc. v. Buckeye Federal
holding that a senior lien holders cancellation of a loan to third party trustors and taking of a quitclaim deed from the trustors in lieu of foreclosure violated the automatic stay of the junior lien holder who was a debtor in bankruptcy holding that operation of state law requiring lien holder to renew lien in state court was not stayed by section 362 because extension  simply allows the holder of a valid lien to maintain the status quo  a policy not adverse to bankruptcy law but rather in complete harmony with it holding that despite foreclosure judgment providing that the holder of a junior mortgage had no interest in or lien on or claim to said premises the lack of foreclosure sale meant that the junior mortgage was not extinguished holding that a lien holder who is not served and joined as a party to a tax suit cannot have his lien extinguished by the tax sale 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