OPINION AND ORDER
ENRIQUE S. LAMOUTTE, Bankruptcy Judge.
The issue before the court is whether Banco Popular de Puerto Rico (hereinafter referred to as "BPPR") or the United States Internal Revenue Service (hereinafter referred to as the "IRS") is the senior lien holder over Debtor's cash collateral, in particular, the Debtor's accounts receivables generated on or after March 1, 2010, in accordance with 26 U.S.C. §§ 6321, 6322 and 6323 ...
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