Read the following excerpt from a US court opinion:
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in bankruptcy. As of November 23, 2005, the Debtor owed the Creditor approximately $114,040. A debtor cannot claim an exemption against amounts owed on a secured debt that represents a voluntary encumbrance of property; consequently, the Debtor is not entitled to any exemption in the $114,040 owed to the Creditor. Because the Debtor’s principal residence was sold for $130,000, the Debtor’s entitlement to an exemption based on the transfer sought to be avoided was only $15,960. Assuming that all four of the requirements are met, a debtor has the right to avoid the transfer of his property to the extent that he could have exempted such property. See Compton v. Compton (In re Compton), No. 97-31367DWS, 1998 WL 372659, **4-5, 1998 Bankr.LEXIS 744, *13-14 (Bankr.E.D.Pa. June 22, 1998) ; Davis v. Victor Warren Properties, Inc. (In
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What is the most suitable continuation to the opinion? Your options are:
A. 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
B. holding that chapter 20 debtor could not avoid lien because of ineligibility for discharge
C. holding state courts authority under iowa code section 59821 not the lien created there under prevented debtor from claiming the iowa homestead exemption and therefore the debtor could not avoid the lien because the lien did not impair an exemption to which the debtor would have been entitled but for the lien
D. holding that a chapter 13 debtor had standing to avoid a judgment lien to the extent of her exemption amount but not the entire judgment lien
E. holding that the debtor had standing to avoid a foreclosure sale under  522 but only to the extent of her 5000 exemption
Reply with [A, B, C, D, E] only.