Let me make clear that, when I said "Zero Fill", I meant a utility that writes zeros to EVERY Sector. I did NOT mean a File Wipe utility that writes Zeroes only to those Sectors already involved in every known file. In fact, one Zero Fill utility free from a major HDD maker says that, if you choose its very thorough option (not a quick Zero-Fill), it will write ones everywhere, THEN overwrite again with zeroes. If that is done to even the first Sector (no. 0) of the first track of the first side of the HDD, whatever was there will be erased. There are several freeware utilities that can do this, too.
Now, I realize that this is NOT a military-grade data destructor, so it IS possible for sophisticated tools to recover the original data after such a Zero Fill. But no MBR virus can self-resurrect after being overwritten like that.
I also realize that simply re-writing the MBR (via FIXMBR, for example) will not do the job either because it re-writes only the key portions of the first track that are supposed to contain the boot loader code. It does not actually overwrite ALL of the first track of the HDD.