In re Adams, 373 B.R. 116, 121 (10th Cir. BAP 2007).See In re Nicholes, 184 B.R. 82, 90 (9th Cir. BAP 1995) (acknowledging that nature of dispute over liability may, in some cases, cause a claim to be classified as unliquidated); In re Denaeyer, No. BK11–43089–TLS, 2012 WL 1605555 (Bankr.D.Neb. May 8, 2012) (concluding debtor's tort claim could not be used to “chip away” at a liquidated debt). This is especially troubling where Mr. Cannon admits to the existence of the claims for the purpose of receiving a discharge under Chapter 13, while at the same time denying their existence.