The IRS seized all of debtor's inventory, equipment, and other property from its business, causing debtor to cease its operations. Debtor filed a chapter 11 petition while the property was still in possession of the IRS and had not been sold, and filed an adversary complaint for turnover. The court held that a debtor's interest in property that was seized by the IRS prepetition is property of the estate, subject to turnover under 11 U.S.C. § 542. The court rejected the IRS' argument, based on pre-Code case law, that a levy on property under 26 U.S.C. § 6331 divests the debtor of any interest in the property, concluding that the IRS levy gave it a perfected lien, and therefore a substantial interest in the property, but not one that equals absolute ownership. Since all of the property seized was necessary to debtor's business, turnover was appropriate, subject to adequate protection of the IRS' interest.