Task: Text Completion
Input (English): would allow him to enjoy an exemption provided by § 522(b).”). However, there is now agreement that the 1994 amendment to § 522(f), by adding the formula set forth in § 522(f)(2)(A), eliminated the need for a debtor to demonstrate the existence of equity in their property in order to avoid the fixing of a judicial lien. In re Higgins, 201 B.R. 965, 967 (9th Cir. BAP 1996). In particular, by adding the phrase, “to the extent that the sum ... exceeds the value that the debt- or’s interest in the property would have in the absence of any liens,” to the formula set forth in § 522(f)(2)(A), it is clear that Congress intended to eliminate the need for a debtor to have equity in property in order to avoid a judicial lien. See, e.g., In re Freeman, 259 B.R. 104, 110 (Bankr.D.S.C.2001) (<HOLDING>). Bolstering this position is the amendment’s 
 Holding statements: (A) holding that a retained equity interest is property even if it has no market value (B) holding  he who seeks equity must do equity  (C) holding that an action for specific performance lies in equity (D) 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 (E) holding that the formula in section 522f2a creates equity for purposes of lien avoidance even if debtors otherwise have no equity in the property
Output (English): (E)