According to the bankruptcy Code, a contingent claim is one that the debtor disputes in entirety. Both the amount and liability are denied, and no provision is made for a Chapter 13 payment through the plan. An unliquidated liability however is one that the debtor readily accepts as valid, yet the amount owed remains uncertain. A Chapter 13 plan must make provisions for payment of unliquidated liabilities, yet the amount of payment may remain in flux for an indefinite period of time. Any creditor who receives notice of a Chapter 13 cases, claiming contingent status for a claim, must appear in court and defend their claim, or the claim will be lost without further payment.