The debtor filed an objection to a claim filed by the Internal Revenue Service.  The debtor conceded that under 26 U.S.C. § 6321 the IRS’s tax lien did create a lien on two of its bank accounts but argued that the lien was junior and inferior to the holders of checks which had been issued by the debtor pre-petition and were outstanding at the time the debtor filed its bankruptcy petition.  The Court concluded that the law is clear that the bankruptcy estate includes the full balance of any non-payroll or other non-trust bank account owned by the bankruptcy debtor as of the commencement of the bankruptcy case.  Even if the payees of these checks honored after filing would have a defense by virtue of § 6323(b)(1)(A) to the IRS’s enforcement of its lien against them outside of bankruptcy, the Court concluded that such fact would not affect the amount of the government’s secured claim against the bankruptcy estate “as of the date of filing” under § 502(b) of the Bankruptcy Code.