Liens can be stripped off of the debtor’s assets in Chapter 11 or Chapter 13 proceedings when there is not enough equity in the asset, after deducting senior liens from the property’s current market value, to secure the unsecured in whole or in part, where the lien exceeds the value of the debtor’s property.  Section 506 of the Bankruptcy Code acknowledges that a lien is only a secured claim to the extent there is value in the asset to which it attaches.  To the extent that the claim exceeds the value of the collateral, that portion of the claim is unsecured. In Chapter 11 or Chapter 13, even voluntary liens, such as mortgages and security interests, can be stripped down to the value of the collateral, with the exception of voluntary liens secured only by the debtor’s residence. Unfortunately Congress has thus far failed to change to bankruptcy law to allowing the modification of home mortgages.  On June 4, the United States Bankruptcy Court for the Eastern District of Michigan adopted ‘Guideline 12.’  This guideline applies to any Chapter 13 case in which a debtor proposes to strip a junior lien on real property under