Cite as: 510 U. S. 43 (1993)
Opinion of the Court
mous Court, Justice Brandeis explained that under the tax laws "[f]ormal notice of the tax liability is thus given; the Commissioner is required to answer; and there is a complete hearing de novo . . . . These provisions amply protect the [taxpayer] against improper administrative action." Id., at 598-599; see also Commissioner v. Shapiro, 424 U. S. 614, 631 (1976) ("[In] the Phillips case . . . the taxpayer's assets could not have been taken or frozen . . . until he had either had, or waived his right to, a full and final adjudication of his tax liability before the Tax Court (then the Board of Tax Appeals)").
Similar provisions remain in force today. The current Internal Revenue Code prohibits the Government from levying upon a deficient taxpayer's property without first affording the taxpayer notice and an opportunity for a hearing, unless exigent circumstances indicate that delay will jeopardize the collection of taxes due. See 26 U. S. C. §§ 6212, 6213, 6851, 6861.
Just as the urgencies that justified summary seizure of property in the 19th century had dissipated by the time of Phillips, neither is there a plausible claim of urgency today to justify the summary seizure of real property under § 881(a)(7). Although the Government relies to some extent on forfeitures as a means of defraying law enforcement expenses, it does not, and we think could not, justify the pre-hearing seizure of forfeitable real property as necessary for the protection of its revenues.
D
The constitutional limitations we enforce in this case apply to real property in general, not simply to residences. That said, the case before us well illustrates an essential principle: Individual freedom finds tangible expression in property rights. At stake in this and many other forfeiture cases are the security and privacy of the home and those who take shelter within it.
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