Devona Ferrel v. Ann Brown, Seattle District Director of Internal Revenue Timothy A. Towns, Chief, Collection Branch

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 court’s opinion. She asserts that the levy on her account violated 26 U.S.C. § 6331(f) because it was uneconomical. However, that section has no relevance to this case because “§ 6331 ... does not ‘implicate the rights of third parties’....”…