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On August 24, 1998, respondent made the following assess-
ments on Form 23C, Assessment Certificate--Summary Record of
Assessments (Form 23C),2 “per default of 90 day letter”, of
petitioners’ tax liability for each of their taxable years 1993
and 1994 and sent a so-called notice of balance due to petition-
ers with respect to each of those years, and on August 31, 1998,
respondent made the following assessments on Form 23C, “per
default of 90 day letter”, of petitioners’ tax liability for each
of their taxable years 1995 and 1996 and sent a notice of balance
due with respect to each of those years:
1993 1994 1995 1996
Deficiency $2,044.00 $2,516.00 $6,082.00 $9,352.90
Late filing 429.25 143.00 1,192.00 1,757.48
penalty
Accuracy-related408.80 263.20 -- --
penalty
Estimated tax –- -- 250.61 360.43
penalty
Interest on 1,187.04 339.42 1,374.78 1,118.61
deficiency
At a time not disclosed by the record prior to November 25,
1998, petitioners received notice from respondent that respondent
intended to issue a notice of levy with respect to their taxable
years 1993 through 1995. On November 25, 1998, respondent issued
a notice of levy with respect to those taxable years to each of
the following banks: First Independent Bank in Vancouver,
2The record does not contain Form 23C, Assessment
Certificate--Summary Record of Assessments, that the Commissioner
of Internal Revenue uses to assess the tax liabilities of taxpay-
ers. However, we have obtained and take judicial notice of that
form.
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