Law360, New York (June 28, 2012, 3:17 PM EDT) -- The ability to discharge debts (i.e., liability on a claim) is essential to the fundamental goal of Chapter 11 of the Bankruptcy Code — providing debtors with a fresh start by resolving all claims that arose before confirmation of the debtor's plan of reorganization. In determining the universe of debts eligible for discharge, Third Circuit courts labored for many years under Avellino v. M. Frenville Co. (In re M. Frenville Co.), 744 F.2d 332 (3d Cir. 1984), which held that a claim arises when a right to payment accrues under applicable nonbankruptcy law. Courts in other jurisdictions almost unanimously rejected Frenville's "accrual" test because it seemed to be at odds with the Bankruptcy Code's broad definition of "claim."...