MEMORANDUM OPINION
JOHN E. RYAN, Bankruptcy Judge.
Debtor brought a motion for use of cash collateral in the form of an account receivable in which the Internal Revenue Service ("IRS") held a perfected security interest. IRS had given proper notice of levy before debtor filed its Chapter 11 petition, and asserted that the account receivable was not property of the bankruptcy estate. After a hearing on November 21, I took the matter under submission.
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