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The issue is whether notice given to Ps that funds had been seized complied with 26 U.S.C. § 6335(a). If not, argue Ps, the levy was not completed before the statute of limitations lapsed, so that the IRS was time-barred from collecting the deficiency. D levied Ps funds to pay unpaid taxes. Ps filed suit claiming lack of notice as required by federal law. The court took judicial notice that banks send monthly statements to their depositors and that those statements were enough to satisfy the notice requirements of §6335(a). Ps appealed. The court of appeals affirmed. In their petition for rehearing, Ps argued that the court had improperly taken judicial notice without giving Ps an opportunity to be heard.

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