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FERREL v. BROWN

No. 93-36106.

40 F.3d 1049 (1994)

Devona FERREL, Plaintiff-Appellant, v. Ann BROWN, Seattle District Director of Internal Revenue; Timothy A. Towns, Chief, Collection Branch, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided November 25, 1994.

Attorney(s) appearing for the Case

Robert E. Kovacevich, Spokane, WA, for plaintiff-appellant.

Gary R. Allen, Tax Div., U.S. Dept. of Justice, Washington, DC, and Diane E. Tebelius, Asst. U.S. Atty., Seattle, WA, for defendants-appellees.

Before: BEEZER and FERNANDEZ, Circuit Judges, and ORRICK, District Judge.

PER CURIAM:

We have carefully reviewed the record and the district court's decision. We affirm for the reasons fully explicated in the district court's excellent published opinion—Ferrel v. Brown, 847 F.Supp. 1524 (W.D.Wash.1993). We adopt that opinion as our own.

Ferrel does raise one issue that was mentioned in her complaint but was not decided in the district...

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