RATLIFF, Judge.
STATEMENT OF THE CASE
Plaintiffs-appellants, David A. Slebodnik et al. (Taxpayers), appeal from the granting of a motion for summary judgment in favor of defendants-appellees, City of Indianapolis et al. (City) on the sole issue of notice. We affirm.
FACTS
On March 15, 1978, more than two thousand property owning Taxpayers of Marion County, Indiana, brought suit to enjoin the implementation of Resolution No. 2261— 1977 of the Board of Public Works of the City of Indianapolis and to have it declared invalid and rescinded. The City-County Council had approved the resolution on February 13,1978, as General Resolution No. 1, 1978. Said resolution incorporated Taxpayers’ lands into the Indianapolis Sanitary District pursuant to I.C. 19-2-14-7 and made the properties subject to a special tax for the retirement of the bonded indebtedness of the Indianapolis Sanitary District. According to evidence stipulated by the parties, the taxes actually levied ranged from approximately $10 to $200 per parcel of real estate, or from between 27 and 28 cents per $100 of valuation, with most parcels being taxed at the lower end of the range. Both sides moved for summary judgment on the issue of notice. The trial court found in favor of the City.
ISSUE
The only issue presented for our review is whether or not notice solely by publication as provided by I.C. 19-2-14-7 in this case violates the requirements of due process of law guaranteed by both the Federal and the Indiana constitutions. We hold that it does not.
DISCUSSION AND DECISION
In appeals based on the granting of a motion for summary judgment, our efforts are directed toward ascertaining the existence of a genuine issue of fact. In the absence of such issue here, we direct our [856]*856attention to whether or not the appellee is entitled to judgment in his favor as a matter of law. Ind.Rules of Procedure, Trial Rule 56; State Board of Tax Commissioners v. Oliverius, (1973) 156 Ind.App. 46, 294 N.E.2d 646, transfer denied.
In this case all parties agree that notice of the proceedings resulting in the Indianapolis-Marion County Council’s approval of General Resolution No. 1,1978, was published in strict compliance with I.C. 19-2-14-71 and that publication is all that is required [857]*857by the statute. Taxpayers do not contend that the statute is unconstitutional because it does not require notice by mail in all cases, but rather argue that notice by publication under the circumstances was inadequate because it was not reasonably calculated to inform them of governmental action which adversely affects their property interests. They claim that because their names and addresses were readily available to the City, both the United States and the Indiana constitutions entitle them to mailed notice. They base their contention on the decisions in Mullane v. Central Hanover Bank and Trust Co., (1950), 339 U.S. 306, 70 S.Ct. 652, 94 L.Ed. 865 (hereinafter denominated Mullane) and Fritz v. Board of Trustees of Town of Clermont, (1969) 253 Ind. 202, 252 N.E.2d 567 (hereinafter denominated Fritz, I ).2 The City, of course, contends that notice by publication as required by the statute was adequate under both the Mullane and Fritz decisions.
In Mullane the United States Supreme Court held that notice by publication to beneficiaries of a common trust fund upon application for judicial settlement of accounts pursuant to a New York Banking statute was inadequate where many of the beneficiaries lived outside of New York City and where the names and addresses of the beneficiaries were known and readily available. The Court there stated that “[a]n elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice [858]*858reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” 399 U.S. at 314, 70 S.Ct. at 657.
In Fritz, I, the Indiana Supreme Court applied the Muliane holding to a case involving an assessment for a sanitary sewer system in the Town of Clermont. The applicable statutes (now embodied in Ind.Code 19-2-7-1 et seq.) provided for notice only by publication at each of the various stages of the proceedings up to and including the final assessment for construction of the sewers. There was no question but that all the statutory procedures regarding notice had been strictly complied with. The town had published notice of the initial hearing with regard to Resolution 1968-1 which was passed by the Board of Trustees and which created the sanitary district. No remonstrance having been made, Resolution 1968-2 confirming Resolution 1968-1 was passed. Later the Board passed Resolution 1968-3 which provided for the filing of an assessment role and for a hearing thereon. Notice of the hearing to be held regarding the assessment role was likewise published. Again no remonstrance was made, and Resolution 1968 — 4 making the assessment roll final was confirmed, resulting in a final assessment against the Fritzes’ property of $17,827.44. The Fritzes brought an action seeking to enjoin enforcement of the sewer assessment, and the trial court granted a motion for summary judgment in favor of the Town of Clermont. On appeal the Indiana Supreme Court reversed, saying at 252 N.E.2d 568-569:
“We believe the notice given under these circumstances was not a notice reasonably calculated to apprise interested parties of the proceedings which were intended to affect the property of appellants specifically.
“From the practicalities of the situation we can reach no other conclusion than that fairness and justice require that the appellant in this case should have had personal notice of the proposed action with reference to the sewer project. Even the minimum in that respect would require a letter through the mail, addressed personally to the property owners affected by the special assessments.”
The court went on, however, to distinguish two types of hearings involved in such proceedings and the requisite notice for each at 252 N.E.2d 571.
“We point out that there are two types of hearings in proceedings of this character which should be distinguished. There is the hearing that normally takes place to determine the pros and cons or the merits of the project as a whole as a public improvement. Then there is the second step where the public authority seeks to reach and affect certain specific property, normally real estate, against which a special assessment and lien is to be applied, or in some instances, as in condemnation proceedings, the property itself is to be taken. In the first instance, where the hearing is for the benefit of the public generally, a notice of a general nature to the public in general would seem to suffice.
“ ‘. . . There is no constitutional privilege to be heard in opposition at the launching of a project which may end in an assessment.
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RATLIFF, Judge.
STATEMENT OF THE CASE
Plaintiffs-appellants, David A. Slebodnik et al. (Taxpayers), appeal from the granting of a motion for summary judgment in favor of defendants-appellees, City of Indianapolis et al. (City) on the sole issue of notice. We affirm.
FACTS
On March 15, 1978, more than two thousand property owning Taxpayers of Marion County, Indiana, brought suit to enjoin the implementation of Resolution No. 2261— 1977 of the Board of Public Works of the City of Indianapolis and to have it declared invalid and rescinded. The City-County Council had approved the resolution on February 13,1978, as General Resolution No. 1, 1978. Said resolution incorporated Taxpayers’ lands into the Indianapolis Sanitary District pursuant to I.C. 19-2-14-7 and made the properties subject to a special tax for the retirement of the bonded indebtedness of the Indianapolis Sanitary District. According to evidence stipulated by the parties, the taxes actually levied ranged from approximately $10 to $200 per parcel of real estate, or from between 27 and 28 cents per $100 of valuation, with most parcels being taxed at the lower end of the range. Both sides moved for summary judgment on the issue of notice. The trial court found in favor of the City.
ISSUE
The only issue presented for our review is whether or not notice solely by publication as provided by I.C. 19-2-14-7 in this case violates the requirements of due process of law guaranteed by both the Federal and the Indiana constitutions. We hold that it does not.
DISCUSSION AND DECISION
In appeals based on the granting of a motion for summary judgment, our efforts are directed toward ascertaining the existence of a genuine issue of fact. In the absence of such issue here, we direct our [856]*856attention to whether or not the appellee is entitled to judgment in his favor as a matter of law. Ind.Rules of Procedure, Trial Rule 56; State Board of Tax Commissioners v. Oliverius, (1973) 156 Ind.App. 46, 294 N.E.2d 646, transfer denied.
In this case all parties agree that notice of the proceedings resulting in the Indianapolis-Marion County Council’s approval of General Resolution No. 1,1978, was published in strict compliance with I.C. 19-2-14-71 and that publication is all that is required [857]*857by the statute. Taxpayers do not contend that the statute is unconstitutional because it does not require notice by mail in all cases, but rather argue that notice by publication under the circumstances was inadequate because it was not reasonably calculated to inform them of governmental action which adversely affects their property interests. They claim that because their names and addresses were readily available to the City, both the United States and the Indiana constitutions entitle them to mailed notice. They base their contention on the decisions in Mullane v. Central Hanover Bank and Trust Co., (1950), 339 U.S. 306, 70 S.Ct. 652, 94 L.Ed. 865 (hereinafter denominated Mullane) and Fritz v. Board of Trustees of Town of Clermont, (1969) 253 Ind. 202, 252 N.E.2d 567 (hereinafter denominated Fritz, I ).2 The City, of course, contends that notice by publication as required by the statute was adequate under both the Mullane and Fritz decisions.
In Mullane the United States Supreme Court held that notice by publication to beneficiaries of a common trust fund upon application for judicial settlement of accounts pursuant to a New York Banking statute was inadequate where many of the beneficiaries lived outside of New York City and where the names and addresses of the beneficiaries were known and readily available. The Court there stated that “[a]n elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice [858]*858reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” 399 U.S. at 314, 70 S.Ct. at 657.
In Fritz, I, the Indiana Supreme Court applied the Muliane holding to a case involving an assessment for a sanitary sewer system in the Town of Clermont. The applicable statutes (now embodied in Ind.Code 19-2-7-1 et seq.) provided for notice only by publication at each of the various stages of the proceedings up to and including the final assessment for construction of the sewers. There was no question but that all the statutory procedures regarding notice had been strictly complied with. The town had published notice of the initial hearing with regard to Resolution 1968-1 which was passed by the Board of Trustees and which created the sanitary district. No remonstrance having been made, Resolution 1968-2 confirming Resolution 1968-1 was passed. Later the Board passed Resolution 1968-3 which provided for the filing of an assessment role and for a hearing thereon. Notice of the hearing to be held regarding the assessment role was likewise published. Again no remonstrance was made, and Resolution 1968 — 4 making the assessment roll final was confirmed, resulting in a final assessment against the Fritzes’ property of $17,827.44. The Fritzes brought an action seeking to enjoin enforcement of the sewer assessment, and the trial court granted a motion for summary judgment in favor of the Town of Clermont. On appeal the Indiana Supreme Court reversed, saying at 252 N.E.2d 568-569:
“We believe the notice given under these circumstances was not a notice reasonably calculated to apprise interested parties of the proceedings which were intended to affect the property of appellants specifically.
“From the practicalities of the situation we can reach no other conclusion than that fairness and justice require that the appellant in this case should have had personal notice of the proposed action with reference to the sewer project. Even the minimum in that respect would require a letter through the mail, addressed personally to the property owners affected by the special assessments.”
The court went on, however, to distinguish two types of hearings involved in such proceedings and the requisite notice for each at 252 N.E.2d 571.
“We point out that there are two types of hearings in proceedings of this character which should be distinguished. There is the hearing that normally takes place to determine the pros and cons or the merits of the project as a whole as a public improvement. Then there is the second step where the public authority seeks to reach and affect certain specific property, normally real estate, against which a special assessment and lien is to be applied, or in some instances, as in condemnation proceedings, the property itself is to be taken. In the first instance, where the hearing is for the benefit of the public generally, a notice of a general nature to the public in general would seem to suffice.
“ ‘. . . There is no constitutional privilege to be heard in opposition at the launching of a project which may end in an assessment. It is enough that a hearing is permitted before the imposition of the assessment as a charge upon the land .. .. ’ Utley v. City of St Petersburg (1934), 292 U.S. 106, 54 S.Ct. 593, 78 L.Ed. 115; 48 Am.Jur., Special & Local Assessments, § 169.
“When, however, the proceedings reach the point where it affects specific pieces of property owned by specific individuals, the intentions of the public authority to seize or take an interest or make an assessment against such property should be made known to the individual affected by means which are reasonably calculated to give such person actual notice.”
Subsequently, in Fritz, II, (see footnote 2) the Court of Appeals upheld the trial court’s judgment resulting in the $17,827.44 assessment against the Fritzes’ property on the issue of benefits after proper notice and hearing requirements had been met.
[859]*859Taxpayers argue that the case at hand involves a combination of the two types of proceedings distinguished in Fritz, I, because the incorporation of their properties into the sanitary district pursuant to I.C. 19-2-14-7 resulted in an immediate tax against their properties. They contend that such special taxes are assessments spread pro rata as to value for which they received no benefits and for which they were entitled to better notice than publication in the back pages of their local newspapers. They state that such notice was not reasonably calculated to inform them of the proceedings and thus prevented them from remonstrating against the resolution and its concomitant assessment. The City, on the other hand, contends that the hearing contemplated by I.C. 19-2-14-7 was purely of the first type analyzed in Fritz, I, and therefore that notice by publication was adequate since the proceeding involved a resolution incorporating additional territory into the sanitary district and was not a levy of assessments for specific improvements which might result at some later date because of the incorporation action. The City readily agrees that before a specific assessment in the nature of the one involved in both Fritz cases is made against the Taxpayers’ properties for the construction of sewers pursuant to I.C. 19-2-16-1 et seq., notice by mail concerning the proceedings thereon is statutorily, if not constitutionally, required. We agree with the City.
It is a general postulate that any analysis of procedural due process must begin with a determination of what process is actually due. It could not be suggested seriously that just because their names and addresses are readily available to the City in the records of the auditor’s office all property owners in Marion County are automatically entitled to notice by mail before the City-County Council takes some action which results in a tax upon the property owners. Assessments for special improvements such as a sewer system involve procedural considerations which are applicable to the legitimate exercise of a government’s sovereign power of taxation, and not its power of eminent domain. See, 14 E. McQuillin, Municipal Corporations, Special Taxation and Local Assessments, § 38.01 (1970). Thus, the “taking” question is not properly raised here.
There is no legal principle of constitutional dimension requiring notice to be provided persons who will be affected by general tax legislation, but the Legislature may provide for such notice as it deems advisable, regardless of whether or not taxpayers think it is sufficient. Board of County Commissioners of Lake County v. Sims, (1969) 252 Ind. 531, 251 N.E.2d 9. The Legislature also has the power to create special taxing districts for the purpose of funding local improvements. Johnson v. Board of Park Commissioners, (1930) 202 Ind. 282, 174 N.E. 91; Martin v. Ben Davis Conservancy District, (1958) 238 Ind. 502, 153 N.E.2d 125; Book v. Board of Flood Control Commissioners, (1959) 239 Ind. 160, 156 N.E.2d 87; Dortch v. Lugar, (1971) 255 Ind. 545, 266 N.E.2d 25. Likewise, the method to be used in securing funds for a special public improvement, such as a park or sewer system, within a taxing district-is for the Legislature to determine. Johnson v. Board of Park Commissioners, supra; Department of Public Sanitation of Hammond v. Solan, (1951) 229 Ind. 228, 97 N.E.2d 495. Indiana follows the general rule that no part of a taxing district may be made to pay a greater proportional tax than any other and no part of a district may be taxed without imposing a tax on the balance of the area. 16 E. McQuillin, Municipal Corporations, Taxation, § 44.21 (1979); Johnson v. Board of Park Commissioners, supra. Thus, upon incorporation of Taxpayers’ properties into the Indianapolis Sanitary District they rightfully became subject to the same proportional tax as the rest of the property in the district. As pointed out by our Supreme Court in Fritz, I, due process of law either under Mullane or in Indiana does not require avenues of protest at every stage of proceedings, the consequences of which result in the imposition of a tax or assessment. According to Fritz, I, it is when the proceedings reach the point of affecting specific pieces of [860]*860property owned by specific individuals that the intentions of the public authority to make an assessment against such property should be made known to the individual affected “by means which are reasonably calculated to give such person actual notice.” 252 N.E.2d at 571. We note that the type of assessment to which Taxpayers’ properties became subject as a result of the City’s action here was not a specific assessment for the actual construction of sewers as was involved in the two Fritz cases, but rather a general assessment applicable to each property pro rata as to value without the specific benefit as opposed to with the benefit. Taxpayers, thus, seem to us to have confused the levy of a general type of assessment for the general benefits derived from being included in the sanitary district in this case with the specific pro rata assessments for specific benefits which would be conferred upon the properties involved when sewer service is actually provided. The fact that no specific benefits were received in this case is irrelevant since the Fourteenth Amendment does not require that tax liability of the type involved here be measured by benefits derived. 16 E. McQuillin, Municipal Corporations, Taxation, § 44.21 (1979). The point at which Taxpayers may contest the benefits issue, as reflected in Fritz, II, is upon assessment for benefits actually provided. It is at this stage also that notice by mail has been specified by I.C. 19-2-16-1 et seq.
In the instant case the type of assessment involving the retirement of bonded indebtedness of the taxing corporation is similar to that to which property becomes subject when annexed to a city or other municipal corporation. The Legislature itself suggested this analogy by providing in the final sentence of I.C. 19-2-14-7 that “such proportion of taxation shall be determined in the same manner as when any territory is annexed to a city, and the applicable statutes thereon are here included by this reference thereto.” (See footnote 1 above.) Taxpayers have cited us to no case and we have found no authority stating that any type of notice is constitutionally required when an annexation question is involved. Indeed, all authority in Indiana and elsewhere is to the contrary. See, e. g., Board of County Commissioners of Lake County v. Sims, (1969) 252 Ind. 531, 251 N.E.2d 9; 2 E. McQuillin, Municipal Corporations, Corporate Boundaries and Subdivisions, § 7.35 (1979).
“The rationale behind a rule not requiring notice prior to the expansion by a municipality of its boundaries is that the adoption of an ordinance expressing the intent to expand is purely a legislative matter and constitutes a finding of public necessity and convenience by the governing authorities. Under such procedures due process is afforded with respect to notice and a hearing when the matter of adoption of the ordinance is submitted to a court for ratification and confirmation.” 2 E. McQuillin, supra, at 466.
The same principle is equally true with regard to taxation uniformly assessed against all property in the same municipal corporation. Board of County Commissioners of Lake County v. Sims, supra.
It is important in this context to note that tax proceedings are not the same as judicial proceedings and that MuIIane, which involved a judicial proceeding, limited its holding regarding notice specifically to proceedings which are to be accorded finality. (See the quotation from Mullane hereinbefore set out.) Our Legislature has, in fact, provided Taxpayers with a method for challenging a tax assessment such as the one involved in this case in I.C. 6-1.1— 26 — l(4)(ii).3 This statute in effect post[861]*861pones the finality of the assessment until a judicial determination has been made. This is all that Mullane requires. In the context of Fritz, I, due process is satisfied when a hearing is provided before a specific assessment for a specific benefit becomes fixed as a charge against the land. This assessment has not yet been made in the case at bar.
We hold, therefore, that notice by publication as provided by I.C. 19-2-14-7 was adequate under due process considerations of both the United States and the Indiana constitutions in the proceedings which incorporated appellants’ properties into the Indianapolis Sanitary District and pursuant to which certain increases in ad valorem general assessments were levied against appellants’ properties.
Judgment affirmed.
ROBERTSON, P. J., and NEAL, J., concur.