In In re Al Copeland Enterprises, Inc., 133 B.R. 837 (Bankr. W.D. Tex. 1991), the bankruptcy court held that the State could collect the full amount of the trust fund tax due because the debtor had sufficient funds on hand equal to or in excess of the amount owed to the State:
(1) at all times between the date that the debtor collected the taxes and the date he filed for bankruptcy;
(2) on the date the debtor filed for bankruptcy. Id. at 839.