Can ineffective assistance counsel be reviewed in a habeas corpus proceeding?

1 As a general matter, ineffective assistance of counsel claims are best reviewed by way of a habeas corpus proceeding rather than on direct appeal, as collateral attack allows the development of a more complete factual record on this issue. United States v. Birges, 723 F2d 666, 670 (9th Cir 1984). In this case, however, the record has been adequately developed through numerous submissions to, and hearings before, the district court.