relies on In re Lambert, 43 B.R. 913 (Bankr.D.Utah 1984), which opines that "a debt whose liability or amount is disputed ... should not be included in the eligibility calculation.” Id. at 915. We note that the Norton treatise identifies Lambert as the decision that does not follow the vast majority of holdings that include disputed debts in the § 109(e) calculus. See Norton, supra, § 18:12 at 18-43 n. 91. Our court, which has held that "debt” and “claim” are equivalents, In re Energy Co-op, 832 F.2d at 1001, is firmly with the majority. Cf. In re Pulliam, 90 B.R. 241, 244-46 (Bankr.N.D.Tex.1988) (analyzing Lambert's erroneous definitions of "claim” and "debt”). 4 . The case law fully supports this method of determining whether a debt is liquidated. See, e.g., McGovern, 122 B.R. at 717 (<HOLDING>); In re Pulliam, 90 B.R. 241, 244-46
holding that there may be an obligation to defend under an insurance policy even though there is no obligation to indemnify holding debtors obligation to creditor though disputed was liquidated because amount of liability was readily discernible by reference to an agreement or through simple mathematics holding that insurance obligation was primary to indemnity obligation holding that property seized by a creditor prior to debtors bankruptcy was property of the estate even though creditor  the irs  held a secured interest  a tax lien  in the property holding that general obligation to pay money under a disputed provision of the tax code was not a taking