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Plan. While a Chapter 13 debtor has a limited right to bring an avoidance action under § 522(h) of the.They must be given two claims: one fully secured and one fully unsecured. This. 506(d) very clearly says if the secured debt ․ is purporting to secure a disallowed claim, then the lien can be avoided. An auditor's valuation is acceptable if the property is being surrendered or is not subject to lien avoidance, cramdown, or bifurcation. Valuing a Claim or Avoiding a Lien Under 11 U.S.C. § 506 Through the. Plan. Additional Cases and Full Text of Judge Lundin's Treatise available at: LundinOnChapter13. § 506 Through the. Plan. Use this form for avoidance of liens on co-owned property only. Name of creditor and description of property securing lien.