In Re: Murray L. Deutchman, Debtor. Murray L. Deutchman, Debtor-Appellant v. Internal Revenue, 192 F.3d 457 (4th Cir. 1999). · Go Syfert
In Re: Murray L. Deutchman, Debtor. Murray L. Deutchman, Debtor-Appellant v. Internal Revenue, 192 F.3d 457 (4th Cir. 1999). Cases Citing This Book View Copy Cite
“in order to 'provide for' a creditor ... the plan must, at a minimum, clearly and accurately characterize the creditor's claim throughout the plan.”
93 citation events (73 in the last 25 years) across 27 distinct courts.
Strongest positive: Holloway v. Southeast Alabama Medical Center (In Re Holloway) (almd, 2001-04-16)
Treatment trajectory · 1999 → 2026 · click a year to view as-of
1999 2012 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Holloway v. Southeast Alabama Medical Center (In Re Holloway) (3×) also: Cited as authority (rule), Cited "see, e.g."
M.D. Ala. · 2001 · signal: see also · quote attribution · 1 verbatim quote · confidence high
in order to 'provide for' a creditor ... the plan must, at a minimum, clearly and accurately characterize the creditor's claim throughout the plan.
cited Cited as authority (rule) In re: Gerald Roscoe Mollohan v. Brothers of the Wheel MC Executive Council, Inc.
S.D.W. Va · 2025 · confidence medium
Corp. (In re Kielisch), 258 F.3d 315, 319 (4th Cir. 2001)); Deutchman v. Internal Revenue (In re Deutchman), 192 F.3d 457, 459 (4th Cir. 1999).
discussed Cited as authority (rule) Deborah Parker v. Dan Martin
4th Cir. · 2025 · confidence medium
That is, we review findings of fact for clear error and conclusions of law de novo.” In re Deutchman, 192 F.3d 457, 459 (4th Cir. 1999) (internal citations omitted). “ ‘Clear error’ is a ‘very deferential standard of review.’ ” Walsh v. Vinoskey, 19 F.4th 672, 677 (4th Cir. 2021) (quoting United States v. Horton, 693 F.3d 463, 474 (4th Cir. 2012)).
discussed Cited as authority (rule) Gary LeClair v. Lynn Tavenner
4th Cir. · 2025 · confidence medium
Corp. (In re 8 USCA4 Appeal: 23-1131 Doc: 45 Filed: 02/07/2025 Pg: 9 of 15 Kielisch), 258 F.3d 315 , 319 (4th Cir. 2001) (quoting Deutchman v. Internal Revenue (In re Deutchman), 192 F.3d 457, 459 (4th Cir. 1999)).
discussed Cited as authority (rule) Gary LeClair v. Lynn Tavenner
4th Cir. · 2025 · confidence medium
Corp. (In re 8 USCA4 Appeal: 23-1133 Doc: 44 Filed: 02/07/2025 Pg: 9 of 15 Kielisch), 258 F.3d 315 , 319 (4th Cir. 2001) (quoting Deutchman v. Internal Revenue (In re Deutchman), 192 F.3d 457, 459 (4th Cir. 1999)).
discussed Cited as authority (rule) Gary LeClair v. Lynn Tavenner
4th Cir. · 2025 · confidence medium
Corp. (In re 8 USCA4 Appeal: 23-1134 Doc: 44 Filed: 02/07/2025 Pg: 9 of 15 Kielisch), 258 F.3d 315 , 319 (4th Cir. 2001) (quoting Deutchman v. Internal Revenue (In re Deutchman), 192 F.3d 457, 459 (4th Cir. 1999)).
discussed Cited as authority (rule) Roup v. Commercial Research, LLC
Colo. · 2015 · confidence medium
See, e.g., In re Haberman, 516 F.3d 1207, 1209 (10th Cir.2008) ("[L]iens generally pass through bankruptey unaffected. ..."); In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999) ("In order to extinguish or modify a lien, the debtor must take some affirmative step toward that end.").
discussed Cited as authority (rule) Washington v. Green Tree Servicing, LLC (In re Washington)
Bankr. D.S.C. · 2015 · confidence medium
See, e.g., Johnson v. Home State Bank, 501 U.S. 78, 83 , 111 S.Ct. 2150 , 115 L.Ed.2d 66 (1991) (“[A] discharge extinguishes only ‘the personal liability of the debtor.’ ”) (quoting § 524(a)(1)); In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999); In re Tucker, 516 B.R. 340, 345-46 (Bankr.W.D.Va.2014) (citing In re Harlan, 402 B.R. 703, 714 (Bankr.W.D.Va.2009)).
cited Cited as authority (rule) Kohout v. United States Trustee
N.D.W. Va. · 2014 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
discussed Cited as authority (rule) Commercial Research, LLC v. Roup
Colo. Ct. App. · 2013 · confidence medium
See In re Haberman, 516 F.3d 1207, 1209 (10th Cir.2008) ("[Lliens generally pass through bankruptey unaffected."); In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999) ("In order to extinguish or modify a lien, the debtor must take some affirmative step toward that end.").
cited Cited as authority (rule) In Re Sawyer
Bankr. D.S.C. · 2007 · confidence medium
See Banks, 299 F.3d at 302; Cen-Pen Corp., 58 F.3d at 93 ; In re Deutchman, 192 F.3d 457, 460 (4th Cir. 1999), Fed.
cited Cited as authority (rule) Gizzi v. Educational Credit Management Corp.
N.D.W. Va. · 2007 · confidence medium
Deutchman v. IRS (In re Deutchman), 192 F.3d 457, 459 (4th Cir.1999).
discussed Cited as authority (rule) In Re Male
Bankr. E.D.N.C. · 2007 · confidence medium
Ms. James does not assert that she failed to receive proper notice of treatment of her claim in the bankruptcy case. “[I]n order to ‘provide for’ a creditor for purposes of § 1327(c), the plan must, at a minimum, clearly and accurately characterize the creditor’s claim throughout the plan.” Deutchman v. Internal Revenue (In re Deutchman), 192 F.3d 457, 461 (4th Cir.1999).
cited Cited as authority (rule) Matsuda Capital, Inc. v. Netfax Development, LLC (In Re Netfax, Inc.)
Bankr. D. Md. · 2005 · confidence medium
In re Kielisch, 258 F.3d 315 , 319 (4th Cir.2001); In re Deutchman, 192 F.3d 457, 459 (4th Cir. 1999).
discussed Cited as authority (rule) Barnes v. Sawyer (In Re Barnes)
Bankr. M.D. Ala. · 2005 · confidence medium
“A bankruptcy discharge extinguishes only in personam claims against the debtor(s), but generally has no effect on an in rem claim against the debtor’s property.” Deutchman v. Internal Revenue Service (In re Deutchman), 192 F.3d 457, 460 (4th Cir.1999)(citing Cen-Pen Corporation v. Hanson (In re Hanson), 58 F.3d 89, 92 (4th Cir.1995)). *842 The Court notes that had Sawyer’s lien not attached to Barnes’ residence, as of the petition date, then the result here would be different.
cited Cited as authority (rule) Educational Credit Management Corp. v. Gouge
W.D.N.C. · 2005 · confidence medium
Schlossberg v. Barney, 380 F.3d 174, 177 (4th Cir.2004); In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Shaw v. United States Bankruptcy Administrator
M.D.N.C. · 2004 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Ritts v. Grigsby
D. Maryland · 2004 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted).
cited Cited as authority (rule) Whitaker v. CIT Group/Equipment Financing, Inc. (In re Crowell)
unknown court · 2004 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Lynch v. Tate (In Re Lynch)
W.D.N.C. · 2003 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Dean v. McDow
E.D. Va. · 2003 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) United States v. Field (In Re Abatement Environmental Resources, Inc.)
D. Maryland · 2003 · confidence medium
Corp., 258 F.3d 315 , 319 (4th Cir.2001); In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Tidewater Finance Co. v. Moffett (In Re Moffett)
E.D. Va. · 2003 · confidence medium
Id. (citing In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999)); see also Fed.
cited Cited as authority (rule) Martin Marietta Materials, Inc. v. Driggs Corp.
4th Cir. · 2003 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Granati v. Stone Street Capital, Inc. (In Re Granati)
E.D. Va. · 2002 · confidence medium
Id. (citing In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999)).
cited Cited as authority (rule) Uwimana v. Government of Rwanda (In re Uwimana)
D. Maryland · 2002 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted); see also In re Kielisch, 258 F.3d 315, 319 (4th Cir.2001).
cited Cited as authority (rule) Magers v. Bonds, Incorporated
4th Cir. · 2002 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Evabank v. Baxter
N.D. Ala. · 2002 · confidence medium
See, e.g., Adair v. Sherman, 230 F.3d 890, 894-895 (7th Cir.2000); In re Deutchman, 192 F.3d 457, 461 (4th Cir.1999); In re Snow, 270 B.R. 38, 40-42 (D.Md.2001).
cited Cited as authority (rule) Educational Credit Management Corp. v. Buchanan
N.D.W. Va. · 2002 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Keeler v. Academy of American Franciscan History, Inc. (In Re Keeler)
D. Maryland · 2002 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted).
discussed Cited as authority (rule) Hamlett v. Amsouth Bank (In re Hamlett)
Bankr. W.D. Va. · 2002 · confidence medium
DISCUSSION As a general rule, liens pass through bankruptcy unaffected. “[A] bankruptcy discharge extinguishes only in personam claims against the debtor, but generally has no effect on an in rem claim against the debtor’s property.” In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999) (quoting Cen-Pen Corp. v. Hanson, 58 F.3d 89, 92 (4th Cir.1995)).
cited Cited as authority (rule) Education Resources Institute v. Ekenasi (In Re Ekenasi)
S.D.W. Va · 2002 · confidence medium
That is, we review findings of fact for clear error and conclusions of law de novo.” In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted).
cited Cited as authority (rule) Snow v. Countrywide Home Loans, Inc. (In Re Snow)
D. Maryland · 2001 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted).
examined Cited as authority (rule) GE Capital Auto v. Eron (3×) also: Cited "see"
4th Cir. · 2001 · confidence medium
Bankr.P. 7001(2) (requiring the filing of an adversary “proceeding to determine validity, priority, or extent of a lien or other interest in property”); In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999).
cited Cited as authority (rule) Kielisch v. Educational Credit Management Corp.
4th Cir. · 2001 · confidence medium
That is, we review findings of fact for clear error and conclusions of law de novo.” In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999) (internal citations omitted).
discussed Cited as authority (rule) Darden v. Blankenship (In Re Blankenship)
E.D. Va. · 2001 · confidence medium
This is because “a bankruptcy discharge extinguishes only in personam claims against the debtor(s), but generally has no effect on an in rem claim against the debtor’s property.” In re Deutchman, 192 F.3d 457, 460 (4th Cir.1999) (quoting Cen-Pen Corp. v. Hanson, 58 F.3d 89, 92 (4th Cir.1995)).
cited Cited as authority (rule) Blevins v. Avery County Bank (In re Blevins)
W.D.N.C. · 2000 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
discussed Cited as authority (rule) In Re Regional Building Systems, Inc. (2×)
Bankr. D. Md. · 2000 · confidence medium
Deutchman v. Internal Revenue Service (In re Deutchman), 192 F.3d 457, 460 (4th Cir.1999) (part 11(B)); Cen-Pen Corp. v. Hanson, 58 F.3d 89, 92-93 (4th Cir.1995) (part 11(A)).
cited Cited as authority (rule) In Re Demarco
Bankr. M.D. Fla. · 2000 · confidence medium
In re Deutchman, 192 F.3d 457, 461 (4th Cir.1999).
cited Cited as authority (rule) United States v. Munson
C.D. Ill. · 2000 · confidence medium
In re DeLaurentiis Entertainment Group, Inc., 963 F.2d 1269, 1276-77 (9th Cir.1992); In re Deutchman, 192 F.3d 457, 460-61 (4th Cir.1999); In re Davidovich, 901 F.2d 1533, 1539 (10th Cir.1990).
cited Cited as authority (rule) Vermont Student Assistance Corp. v. Coulson (In Re Coulson)
W.D.N.C. · 2000 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
cited Cited as authority (rule) Florsheim Group, Inc. v. Houser Shoes, Inc. (In re Houser Shoes, Inc.)
W.D.N.C. · 2000 · confidence medium
In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
discussed Cited as authority (rule) Stuart, L.L.C. v. First Mount Vernon Industrial Loan Ass'n (In Re Peramco International, Inc.)
E.D. Va. · 2000 · confidence medium
As we have observed in the past, ‘unless the debtor takes appropriate affirmative action to avoid a security interest in property of the estate, that property will remain subject to the security interest following confirmation.’ Id. at 460 (4th Cir.1999) (quoting Cen-Pen Corp. v. Hanson, 58 F.3d 89, 92 (4th Cir.1995)).
discussed Cited "see" Colombo Bank v. Sharp (2×)
4th Cir. · 2009 · signal: see · confidence high
See Deutchman v. IRS (In re Deutchman), 192 F.3d 457, 459 (4th Cir.1999).
cited Cited "see" Videsh Sandiar Nigam Ltd. v. Startec Global Communications Corp. (In Re Startec Global Communications Corp.)
D. Maryland · 2003 · signal: see · confidence high
See In re Deutchman, 192 F.3d 457, 459 (4th Cir.1999).
discussed Cited "see" Universal Suppliers, Inc. v. Regional Building Systems, Inc. (In re Regional Building Systems, Inc.)
4th Cir. · 2001 · signal: see · confidence high
See In re Deutchman, 192 F.3d 457, 461 (4th Cir.1999) (Chapter 13 plan does not provide for a lien “simply by failing or refusing to acknowledge it or by calling the creditor unsecured.”) (internal quotation marks omitted).
discussed Cited "see" In Re: Regional Building Systems, Incorporated
4th Cir. · 2001 · signal: see · confidence high
See In re Deutchman, 192 F.3d 457, 461 (4th Cir. 1999) (Chapter 13 plan does not provide for a lien "simply by failing or refusing to acknowledge it or by calling the creditor unsecured.") (internal quotation marks omitted). 19 If under Chapter 13 a lien can be extinguished only if the plan provides for it, under Chapter 11 a lien can be extinguished so long as the property to which the lien attaches is dealt with by the plan.
cited Cited "see" Banks v. Sallie Mae Servicing Corp. (In Re Banks)
Bankr. W.D. Va. · 2001 · signal: see · confidence high
See In re Deutchman, 192 F.3d 457, 461 (4th Cir.1999).
cited Cited "see" Holloway v. Southeast Alabama Medical Center & Golden Peanut Co. (In Re Holloway)
Bankr. M.D. Ala. · 2000 · signal: see · confidence high
See Deutchman v. Internal Revenue Service (In re Deutchman), 192 F.3d 457 (4th Cir.1999) and Cen-Pen Corporation v. Hanson (In re Hanson), 58 F.3d 89 (4th Cir.1995).
Retrieving the full opinion text from the archive…
In Re: Murray L. DEUTCHMAN, Debtor. Murray L. Deutchman, Debtor-Appellant,
v.
Internal Revenue, Defendant-Appellee
98-2029.
Court of Appeals for the Fourth Circuit.
Sep 21, 1999.
192 F.3d 457
ARGUED: Andrew Martin Croll, Scar-lett & Croll, P.A., Baltimore, Maryland, for Appellant. Thomas James Sawyer, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Robert B. Scarlett, Scarlett & Croll, P.A., Baltimore, Maryland, for Appellant. Loretta C. Argrett, Assistant Attorney General, Gary D. Gray, Lynne A. Battaglia, United States Attorney, United States Department of Justice, Washington, D.C., for Appellee.
Luttig, Motz, Traxler.
Cited by 70 opinions  |  Published

Affirmed by published opinion. Judge TRAXLER wrote the opinion, in which Judge LUTTIG and Judge DIANA GRIBBON MOTZ joined.

OPINION

TRAXLER, Circuit Judge:

This case involves the effect of a confirmed Chapter 13 plan on liens securing a creditor’s claim. Specifically, a debtor appeals from an order of the district court affirming the bankruptcy court’s determination that the completion of the payments due under his Chapter 13 plan would not extinguish hens on his property held by the Internal Revenue Service (“IRS”). We affirm.

I.

Murray L. Deutchman (“Deutchman”) filed a voluntary petition for Chapter 13 bankruptcy on February 2, 1994. At the time, Deutchman owed over $190,000 in tax liabilities to the IRS, most of which were secured by liens on his property.

On April 28, 1994, Deutchman filed an amended Chapter 13 plan (“the plan”), which listed the IRS’s liens but contained conflicting directions as to how the IRS’s claim would be treated. Specifically, the plan did not list the IRS as a secured creditor, which the plan defined as “[t]he owners of secured indebtedness holding debts, demands or claims, of whatever character, for which the owners have a security interest.” Rather, it listed the majority of the IRS’s secured claim as a Class II “Priority Claim,” which, under the plan’s definition, consisted of unsecured claims entitled to priority to the extent allowed by 11 U.S.C.A. §' 507(a)(8) (West Supp.1999). [1] The plan also provided that[*459] the liens of such Class II creditors “shall be considered released and of no effect” upon the payment of all “Allowed Claims” due them. The remainder of the IRS’s secured claim was listed as a Class III claim, which consisted of unsecured dis-chargeable claims.

Additionally, although initially seeming to require payment “in full” of $172,000 of the IRS’s claim, the plan substantially discounted this amount, asserting that approximately $117,000 of the Class II debt was not entitled to priority under § 507 because those amounts represented debts that had become due more than three years prior to the filing of the bankruptcy petition. See 11 U.S.C.A. § 507(a)(8)(A)(i). Hence, the plan apparently mandated payment of only $35,667.31 “to satisfy, in full, the Debtor’s joint obligation, he holds with his wife, to the [IRS].... ”

Two weeks after Deutchman filed the plan, the IRS filed a proof of claim on behalf of the United States in the amount of $190,876.94, the majority of which, $172,579.15, was listed as secured debt, with the remainder, $18,297.79, listed as unsecured. Deutchman did not object to the IRS’s proof of claim.

Pursuant to a notice sent to all creditors, including the IRS, a confirmation hearing on the plan was thereafter held before the bankruptcy court. Although provided with a copy of the plan, the IRS did not attend the confirmation hearing nor otherwise object to confirmation of the plan. The bankruptcy court confirmed Deutehman’s reorganization plan, and no appeal was taken.

Following confirmation, Deutchman began making payments to the IRS under the plan. Two years later, however, Deutchman, in an effort to refinance his property, pledged to pay all remaining amounts owed to the IRS under the plan if the IRS would agree to release its liens on his property. The IRS refused to release the liens, and additionally asserted that Deutehman’s payment of the reduced amounts called for by the plan could not extinguish the liens.

Deutchman then brought this action, seeking a declaratory judgment that the IRS’s liens would be extinguished upon completion of payments due under the plan. The bankruptcy court granted partial summary judgment to the IRS, leaving open the question of the value of the IRS’s secured claim. The parties later agreed that the amount of the IRS’s remaining secured claim was $139,750.89. The district court affirmed; Deutchman appeals.

II.

We review the district court’s decision by applying the same standard of review that it applied to the bankruptcy court’s decision. See Bowers v. Atlanta Motor Speedway, Inc. (In re Southeast Hotel Properties Ltd. Partnership), 99 F.3d 151, 154 (4th Cir.1996). That is, we review findings of fact for clear error and conclusions of law de novo. See id.; Canal Corp. v. Finmnan (In re Johnson), 960 F.2d 396, 399 (4th Cir.1992).

A.

We begin with an overview of the Chapter 13 bankruptcy process as it relates to the events underlying this matter. Section 501 of the Bankruptcy Code governs the filing of proofs of claims or interests by creditors. See 11 U.S.C.A. § 501 (West 1993). If proof of a claim or interest is filed by a creditor and is not objected to, the claim or interest is “deemed allowed.” See 11 U.S.C.A. § 502(a) (West 1993) (“A claim or interest, proof of which is filed under section 501 of this title, is deemed allowed, unless a party in interest ... objects.”). Because Deutchman did not object to the IRS’s proof of claim, the IRS held an allowed secured claim in the amount of $172,579.15.

[*460] The Chapter 13 debtor must file a plan, see 11 U.S.C.A. § 1321 (West 1993), the contents of which are specified under 11 U.S.C.A. § 1322 (West 1993 & Supp.1999). All interested parties must be notified of the requisite court hearing to confirm the plan, at which time any “party in interest may object to confirmation of the plan.” See 11 U.S.C.A. § 1324 (West 1993). In the instant case, the IRS neither appeared at the confirmation hearing nor objected to the confirmation of Deutchman’s plan.

The impact of a confirmed plan on the parties involved in the Chapter 13 reorganization is governed by 11 U.S.C.A. § 1327 (West 1993), which provides:

(a) The provisions of a confirmed plan bind the debtor and each creditor, whether or not the claim of such creditor is provided for by the plan, and whether or not such creditor has objected to, has accepted, or has rejected the plan.
(b) Except as otherwise provided in the plan or the order confirming the plan, the confirmation of a plan vests all of the property of the estate in the debtor:
(c) Except as otherwise provided in the plan or in the order confirming the plan, the property vesting in the debtor under subsection (b) of this section is free and clear of any claim or interest of any creditor provided for by the plan.

Id. (emphasis added). Relying on this section of the Bankruptcy Code, Deutchman contends that, despite the fact that the IRS held an allowed secured claim in the amount of $172,579.15, his confirmed Chapter 13 plan is now res judicata as to the issues before us. Accordingly, Deutch-man seeks a declaration that the property subject to the IRS’s liens will vest in him free and clear of the liens upon payment of the substantially reduced amounts called for by the plan. We disagree.

B.

As a general rule, liens pass through the bankruptcy process unaffected. See Cenr-Pen Corp. v. Hanson, 58 F.3d 89, 92 (4th Cir.1995). This is because “[a] bankruptcy discharge extinguishes only in personam claims against the debt- or^), but generally has no effect on an in rem claim against the debtor’s property.” Id. In order to extinguish or modify a lien, the debtor must take some affirmative step toward that end. As we have observed in the past, “[ujnless the debtor takes appropriate affirmative action to avoid a security interest in property of the estate, that property will remain subject to the security interest following confirmation.” Id.

In the instant case, Deutchman did not take a sufficient affirmative step to modify or extinguish the IRS’s liens. First, if we assume that Deutchman intended to challenge the validity or existence of the IRS’s liens, he failed to effectively do so because he sought no preconfirmation adversary hearing. Second, Deutchman filed no objection to the proof of claim filed by the IRS, sought no valuation hearing pursuant to 11 U.S.C.A. § 506 (West 1993), nor otherwise attempted to modify the lien in any affirmative way. Instead, Deutchman attempted to “provide for” the liens and obtain a favorable result by merely camouflaging his treatment of the IRS’s liens in his plan. [2] Obviously, this was not an appropriate affirmative step; and for the lack of an appropriate affirmative step his effort to avoid the lien fails.

[*461] C.

In so holding, we necessarily reject Deutchman’s claim that, upon payment of the partial amount due the IRS under his plan, his property will nevertheless vest in him free and clear of the IRS’s liens under § 1327(c) because his plan “provided for” the IRS’s claims. Section 1327(c) does not define “provided for.” However, in Rake v. Wade, 508 U.S. 464, 113 S.Ct. 2187, 124 L.Ed.2d 424 (1993), the Supreme Court defined “provided for,” as used in 11 U.S.C.A. § 1325(a)(5) (West 1993), as “to make a provision for or stipulate to something in a plan,” Rake, 508 U.S. at 473, 113 S.Ct. 2187 (internal quotation marks omitted), and, as used in 11 U.S.C.A. § 1328(a)(West 1993), as “makes provision for, deals with, or even refers to a claim,” Rake, 508 U.S. at 474, 113 S.Ct. 2187 (internal quotation marks omitted). This court, in Cewr-Pen, held that, “[a]s a general matter, a plan ‘provides for’ a claim or interest [under § 1327(c)] when it acknowledges the claim or interest and makes explicit provision for its treatment.” 58 F.3d at 94 (emphasis added). We also held that “ ‘[e]ven where confirmed without objection, a plan will not eliminate a lien simply by failing or refusing to acknowledge it or by calling the creditor unsecured.’ ” Id. (quoting Beard, 112 B.R. at 954).

We adhere to this interpretation today. Although acknowledging that the IRS held valid liens against Deutchman’s property, the plan nowhere acknowledged that the IRS’s claims were allowed secured claims by virtue of these liens and Deutchman’s failure to object to the IRS’s proof of claim. Instead, the plan improperly characterized all of the IRS’s claims as Priority II unsecured claims under § 507 and created additional confusion by setting forth an unclear payment schedule.

In Cen-Pen, we discouraged efforts by debtors to misrepresent the nature of their debts, and we made clear that such efforts could not provide a basis for avoiding liens. See id. at 94. We therefore hold that, in order to “provide for” a creditor for purposes of § 1327(c), the plan must, at a minimum, clearly and accurately characterize the creditor’s claim throughout the plan. Accordingly, Deutchman’s plan did not “provide for” the allowed secured claim of the IRS because the plan did not consistently identify any IRS claim as a secured claim. Such lack of clarity could only mislead both the secured creditor and the bankruptcy court, as well as cause improper treatment of the secured claims in the confirmed plan, and we will not condone it.

D.

Another fatal consequence of Deutchman’s plan was its failure to give specific notice to the IRS of Deutchman’s intent to accord the liens less than full protection. See Piedmont Trust Bank v. Linkous (In re Linkous), 990 F.2d 160, 162-63 (4th Cir.1993). Linkous involved a debtor who had failed to provide a secured creditor with information of the debtor’s intent to have the secured claims reevaluated under § 506(a) by the bankruptcy judge at the upcoming confirmation hearing. We held that the lack of adequate notice alone denied the secured creditor due process and that, accordingly, the confirmation order devaluing the claims would not be given preclusive effect. See id. at 163. The same result obtains here. .Deceptive information is equivalent to no notice at all, and for lack of specific notice, Deutchman’s efforts fail.

III.

Accordingly, the judgment of the district court holding that completion of the payments called for under the terms of the confirmed plan could not extinguish the liens is affirmed.

AFFIRMED.

1

. The plan itself referred to 11 U.S.C.A. § 507(a)(7) (West 1993), which was subse[*459] quently recodified at § 507(a)(8).

2

. Deutchman has not satisfactorily explained the basis for reducing the IRS's secured claim, or for eliminating the presumably valid liens upon his property. There is no indication that he believed that the liens were invalid or that the claim was not legitimate. Nor is there any reason to believe that tire property securing the claim was of insufficient value to secure any portion of the claim. Rather, it appears that Deutchman simply attempted to eliminate valid liens securing an unchallenged claim by calling the claim something that everyone agrees it was not — a § 507 unsecured priority claim.