60
Opinion of the Court
U. S. 239 (1921); Bowles v. Willingham, 321 U. S. 503 (1944), and seizures of contaminated food, see North American Cold Storage Co. v. Chicago, 211 U. S. 306 (1908)—was one of executive urgency. "The prompt payment of taxes," we noted, "may be vital to the existence of a government." Springer, supra, at 594. See also G. M. Leasing Corp. v. United States, 429 U. S. 338, 352, n. 18 (1977) ("The rationale underlying [the revenue] decisions, of course, is that the very existence of government depends upon the prompt collection of the revenues").
A like rationale justified the ex parte seizure of tax-delinquent distilleries in the late 19th century, see, e. g., United States v. Stowell, 133 U. S. 1 (1890); Dobbins's Distillery v. United States, 96 U. S. 395 (1878), since before passage of the Sixteenth Amendment, the Federal Government relied heavily on liquor, customs, and tobacco taxes to generate operating revenues. In 1902, for example, nearly 75 percent of total federal revenues—$479 million out of a total of $653 million—was raised from taxes on liquor, customs, and tobacco. See U. S. Bureau of Census, Historical Statistics of the United States, Colonial Times to the Present 1122 (1976).
The federal income tax code adopted in the first quarter of this century, however, afforded the taxpayer notice and an opportunity to be heard by the Board of Tax Appeals before the Government could seize property for nonpayment of taxes. See Revenue Act of 1921, 42 Stat. 265-266; Revenue Act of 1924, 43 Stat. 297. In Phillips v. Commissioner, 283 U. S. 589 (1931), the Court relied upon the availability, and adequacy, of these preseizure administrative procedures in holding that no judicial hearing was required prior to the seizure of property. Id., at 597-599 (citing Act of Feb. 26, 1926, ch. 27, § 274(a), 44 Stat. 9, 55; Act of May 29, 1928, ch. 852, §§ 272(a), 601, 45 Stat. 791, 852, 872). These constraints on the Commissioner could be overridden, but only when the Commissioner made a determination that a jeopardy assessment was necessary. 283 U. S., at 598. Writing for a unani-
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