Task: Wrong Candidate Generation
Input (English): they are not entitled to avoid the judicial lien. DISCUSSION Section 522(f)(1) of the Bankruptcy Code provides that the debtor may avoid most judicial liens “to the extent that such lien impairs an exemption to which the debtor would have been entitled ...” 11 U.S.C. § 522(f)(1) A debtor is entitled to avoid a judicial lien that impairs a homestead exemption even if the debtors have no equity in the property. Kolich v. Antioch Laurel Veterinary Hosp. Inc., (In re Kolich), 273 B.R. 199, 204 (8th Cir. BAP 2002)(citing F.D.I.C. v. Finn (In re Finn), 211 B.R. 780, 782-84 (1st Cir. BAP 1997) and quoting H.R.Rep. No. 835, 103d Cong., 2d Sess. 45 (1994)), aff'd, 328 F.3d 406 (8th Cir.2003). See also Higgins v. Household Fin. Corp. (In re Higgins), 201 B.R. 965, 967-968 (9th Cir. BAP 1996) (<HOLDING>); In re Whitehead, 226 B.R. 539, 541 
 Holding statements: (A) holding that a debt or could only exempt an item of property that exceeded the exemption limit by paying the difference between the value of the property and the exemption limit to the estate (B) holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens (C) holding that a retained equity interest is property even if it has no market value (D) holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit (E) holding that debtor could not avoid a judicial lien where after accounting for unavoidable liens and mortgages he had no equity in the property and therefore no interest on which to avoid the judicial lien
Output (English): holding that a retained equity interest is property even if it has no market value