OPINION
On December 23, 1983, Andrew Driscoll (“debtor”) filed his petition for relief under chapter 13 of the Bankruptcy Code. On April 2, 1984, the IRS filed its claim for the following amounts:
secured tax claim Sl^lSe.íW1
unsecured priority tax claim 970.38
unsecured tax claim 140.82
The debtor’s chapter 13 plan provides for monthly payments of $21.00 per month for thirty-six months for a total pay out under the plan of $756.00. On April 9, 1984, the debtor’s plan was provisionally confirmed from the bench. A ruling on the status of tax claims was reserved until later. An order of confirmation was thereafter entered in the normal form.
In his motion to change the classification of the IRS claims the debtor alleges that he *324had made all payments proposed under the plan “including the prepayment without discount of the monthly payments that were to be made through December 1986.” The debtor argues that having made all payments required under his plan he is now entitled to reclassification of the IRS’s secured claim and as a consequence the discharge of that claim. In his motion the debtor essentially seeks two things. First, he seeks to reclassify the IRS’s secured claim as unsecured and in effect to avoid the tax liens which attach to his exempt assets.2 Second, the debtor seeks a determination that the IRS has waived any objection to his claimed exemptions and to the discharge of its tax claim. A number of arguments, detailed below, are advanced by the debtor in support of his objectives; none have merit.
I.
The debtor’s first argument is that the IRS’s secured claim should be reclassified as unsecured because the chapter 13 estate contained no assets to which the IRS’s tax lien could attach. This erroneous theory is premised on the notion that since the IRS’s claim was undersecured it should be treated as totally unsecured. In Re Frost, 19 B.R. 804 (Bankr.D.Kan.1982), reversed on other grounds, 47 B.R. 961 (D.Kan.1985), is cited in support of this proposition. However, Frost merely holds that a claim is unsecured to the extent that the claim exceeds the value of the collateral securing it. Thus, Frost provides absolutely no support for the debtor’s contention.
The debtor next argues that he may avoid the IRS’s tax lien under 11 U.S.C. § 545(2).3 Section 545(2) allows the trustee to avoid the fixing of a statutory lien on property of the debtor under certain specified circumstances. The IRS lien in question is a statutory lien within the meaning of section 545 and thus may be avoided by the trustee under section 545(2). The debt- or argues that 11 U.S.C. § 1303 grants him the right to utilize all of the trustee’s avoiding powers, including those contained in section 545. However, section 1303 grants a chapter 13 debtor the powers of a trustee only under specified subsections of 11 U.S.C. § 363 and does not purport to grant the debtor any of the trustee’s avoiding powers found in chapter 5 of the Code. The debtor cites In Re Boyette, 33 B.R. 10 (Bankr.N.D.Tex.1983), and in In Re Hall, 26 B.R. 10 (Bankr.M.D.Fla.1982) for the proposition that the debtor has standing to invoke the trustee’s avoiding powers despite the lack of any provision of the Code to that effect. Hall and Boyette rely on the legislative history to section 1303 which provides in relevant part:
Section 1303 of the House Amendment specifies rights and powers that the debt- or has exclusive of the trustees. The section does not imply that the debtor does not also possess other powers concurrently with the trustee. For example, although section 1323 is not specified in section 1303, certainly it is intended that the debtor has the power to sue and *325be sued. 124 Cong.Rec.H. 11,106 (Sept. 28, 1978); S. 17,423 (Oct. 6, 1978).
In Re Hall, 26 B.R. at 11 (quoting legislative history, emphasis in text).
The better view is expressed by In Re Carter, 2 B.R. 321 (Bankr.D.Colo.1980). That opinion held that chapter 13 debtors may not generally utilize the trustee’s chapter 5 avoiding powers. The court specifically rejected the argument that the legislative history of section 1303 requires a contrary result:
The Debtors assert, however, that they are armed with the powers of the Chapter 13 Trustee by operation of law. No Code section supports that view. Various powers of the trustee pursuant to 11 U.S.C. § 363 are granted to the debtor exclusive of the trustee pursuant to 11 U.S.C. § 1303. In addition, 11 U.S.C. § 1304 adds various other powers for a Chapter 13 debtor engaged in business. None of the powers accorded the trustee in Chapter 5 are given to the debtor by these Sections. The legislative history of § 1303 indicates that some powers may be concurrently held by the trustee and the debtor. S.Rep. No. 95-989, 95th Cong., 2nd Sess. 140 (1978), U.S.Code Cong. & Admin.News, p. 5787. That legislative history does not authorize concurrent debtor access to the lien avoidance powers specifically' granted to the trustee in Chapter 5 of the Code. The congressional example of a concurrently held power is the right to sue and be sued. Obviously, the recognition of that power does no violence to the role of the Chapter 13 trustee. Were lien avoidance powers concurrently held, the trustee would effectively lose control over lien avoidance litigation. That result should be avoided, particularly if it is reachable only by implication. When Congress intended debtors to exercise the powers of a trustee in Chapter 11, it explicitly so stated in § 1107(a). Presumably, a section analogous to § 1107(a) would be present in Chapter 13 if that were the congressional intent. The Court concludes that a Chapter 13 debtor has no ‘strong-arm’ power under the Code.
Id. at 322.
The limited power of a chapter 13 debtor to utilize the trustee’s chapter 5 avoiding powers is governed by section 522 of the Code. 11 U.S.C. § 522(h) provides:
(h) The debtor may avoid a transfer of property of the debtor or recover a setoff to the extent that the debtor could have exempted such property under subsection (g)(1) of this section if the trustee had avoided such transfer, if—
(1) such transfer is avoidable by the trustee under section 544, 545, 547, 548, 549, or 724(a) of this title or recoverable by the trustee under section 553 of this title: and
(2) the trustee does not attempt to avoid such transfer.
11 U.S.C. § 522(g) further provides:
(g) Notwithstanding sections 550 and 551 of this title, the debtor may exempt under subsection (b) of this section property that the trustee recovers under section 510(c)(2), 542, 543, 550, 551, or 553 of this title, to the extent that the debtor could have exempted such property under subsection (b) of this section if such property had not been transferred, if—
(1)(A) such transfer was not a voluntary transfer of such property by the debtor; and
(B) the debtor did not conceal such property; or
(2) the debtor could have avoided such transfer under subsection (f)(2) of this section.
Section 522(h) allows the debtor to utilize the trustee’s avoiding powers only when the debtor could have exempted the property under section 522(g)(1). Section 522(g)(1) permits the debtor to exempt under section 522(b) property that the trustee recovers under specified sections of the Code. Section 522(b) of the Code allows the debtor to exempt a broad range of property under either federal or state exemption provisions. See 11 U.S.C. §§ 522(b) and (d). Section 522(f) specifically delineates the power of the debtor to avoid the fixing of liens on any property *326claimed as exempt under section 522(b).4 Conspicuously absent from section 522(f) is any provision allowing the debtor to avoid statutory liens. There is no question that the tax lien which is the subject of this dispute is a statutory lien which may not be avoided under section 522(f). See In Re Mills, 37 B.R. 832 (Bankr.E.D.Tenn.1984):
Legislative history indicates a clear congressional intent to include tax liens within the definition of a statutory lien. The House Committee on the Judiciary observed:
A statutory lien is only one that arises automatically, and is not based on an agreement to give a lien or on judicial action ... Tax liens are also included in the definition of statutory lien. H.R. Rep. No. 95-595, 95th Cong. 1st Sess. 314, reprinted in 1978 U.S.Code Cong. & Ad.News 5787, 5963, 6271.
Id. at 834-835. See also In Re Zerger, 35 B.R. 42, 43 (Bankr.D.Ore.1983); In Re Davis, 22 B.R. 523, 524 (Bankr.W.D.Pa.1981).
Further, section 522(b) and (g)(1) must be read in conjunction with section 522(c) which provides in relevant part:
(c) Unless the case is dismissed, property exempted under this section is not liable during or after the case for any debt of the debtor that arose, or that is determined under section 502 of this title as if such debt had arisen, before the commencement of the case, except—
(1) a debt of a kind specified in section 523(a)(1) or 523(a)(5) of this title; or
(2) a debt secured by a lien that is—
(A)(i) not avoided under subsection (f) or (g) of this section or under section 544, 545, 547, 548, 549, or 724(a) of this title; and
(ii) not void under section 506(d) of this title; or
(B) a tax lien, notice of which is properly filed.
11 U.S.C. § 522(c). Thus it is clear that Congress did not intend to grant chapter 13 debtors the trustee’s power to avoid tax liens.5
*327II.
The debtor argues that because the IRS failed to object to the debtor’s claimed exemptions and failed to file a timely complaint to determine the dis-chargeability of the claimed secured debt that the debt is discharged and the liens are unenforceable. A lien in favor of the IRS for unpaid taxes, interest and penalties arises on demand upon all real and personal property of the taxpayer. 26 U.S.C. § 6321. The lien is perfected by filing notice pursuant to 26 U.S.C. § 6323(a) and (f). The lien remains in effect until the taxes are paid or until the expiration of the statute of limitations for collections. 26 U.S.C. § 6322. In bankruptcy, however, the extent of the IRS’s secured claim is measured by the value of the collateral as of the date of the filing of the bankruptcy petition. 11 U.S.C. § 506(a); In Re Robinson, 39 B.R. 47, 11 B.C.D. 1292 (Bankr.E.D.Va.1984). The lien securing an allowed secured claim for taxes remains valid to the extent of the allowed secured claim. See 11 U.S.C. § 506(d); 522(c). The fact that the IRS failed to object to the debtor’s claimed exemptions is of no consequence since the exempt property in question remains subject to the tax lien under the Code,6 and no section of the Code requires an objection under these circumstances. The fact that the IRS failed to object to dischargeability of the secured tax claims is also irrelevant since only debts of the type listed in section 523(a)(2), (4), and (6) are discharged if the creditor fails to file a complaint to determine dischargeability. The IRS claims at issue here are nondischargeable solely by virtue of section 523(a)(1), (7).
III.
The procedural history of this case reveals clearly that confirmation of the debtor’s plan was only provisional and subject to a final determination at a later date concerning the status of the IRS tax claims. Sections 1322 and 1325 of the Code provide the standards for a confirmable chapter 13 plan. 11 U.S.C. § 1322(a)(2) provides:
(a) The plan shall—
(2) provide for the full payment, in deferred cash payments, of all claims entitled to priority under section 507 of this title, unless the holder of a particular claim agrees to a different treatment of such claim....
11 U.S.C. § 1325(a) provides in relevant part:
*328(a) Except as provided in subsection (b), the court shall confirm a plan if—
(1) the plan complies with the provisions of this chapter and with the other applicable provisions of this title;
(3) the plan has been proposed in good faith and not by any means forbidden by law;
(5) with respect to each allowed secured claim provided for by the plan—
(A) the holder of such claim has accepted the plan;
(B)(i) the plan provides that the holder of such claim retain the lien securing such claim; and
(ii) the value, as of the effective date of the plan, of property to be distributed under the plan on account of such claim is not less than the allowed amount of such claim; or
(C) the debtor surrenders the property securing such claim to such holder....
The requirements set forth by the language quoted above are clear. In a chapter 13 plan all claims entitled to priority under section 507 must be paid in full unless the claimant agrees to different treatment. Similarly with respect to secured claims the chapter 13 plan must provide for full payment of the allowed secured claim and for the retention of the lien securing the claim or in the alternative that the debtor surrender the property securing the claim to the claimant. While the order confirming the debtor’s chapter 13 plan does not expressly deal with the problem raised by the tax claims, the court stated on the record and noted in its proceeding memo of April 9 that the debtor’s plan was confirmed without ruling on the priority of tax claims. The court further stated that tax claims were to be paid on a priority basis until there was a successful objection to the claims. Therefore, it is clear that approval of the plan was conditional.
The precise effect of the conditional approval of the debtor’s chapter 13 plan must now be considered. Section 1328(a) provides:
(a) As soon as practicable after completion by the debtor of all payments under the plan, unless the court approves a written waiver of discharge executed by the debtor after the order for relief under this chapter, the court shall grant the debtor a discharge of all debts provided for by the plan or disallowed under section 502 of this title, except any debt—
(1) provided for under section 1322(b)(5) of this title; or
(2) of the find specified in section 523(a)(5) of this title.
11 U.S.C. § 1328(a) (emphasis added). This section requires the discharge, with two narrow exceptions, of “all debts provided for by the plan.” However, section 1328 must be read in conjunction with the relevant portions of section 1322 and 1325 quoted above. Those sections make clear that a plan which does not provide for the full payment of priority and secured claims is not confirmable.7 The court must therefore revoke confirmation of the debtor’s plan in order to avoid circumvention of the clear requirements of the Code.8
An order may be entered based on this opinion.