See 11 U.S.C. § 1325(a)(4) (distribution to unsecured creditors under a debtor's Chapter 13 plan cannot be less than distribution under Chapter 7). Additionally, once the claim is bifurcated, the Chapter 13 debtor can normally strip the creditor's lien down to its secured value — in essence, allowing the debtor to avoid the unsecured portion of the creditor's lien. In re Burba, 42 F.3d 1388 (6th Cir. 1994); In re Perry, 337 B.R. 649 (Bankr. N.D.Ohio 2005). This process of bifurcating a claim is commonly referred to as cramdown.