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long been settled. Where, as here, adequate opportunity is afforded for a later judicial determination of the legal rights, summary proceedings to secure prompt performance of pecuniary obligations to the government have been consistently sustained." Id., at 595 (footnote omitted).
"Where only property rights are involved, mere postponement of the judicial enquiry is not a denial of due process, if the opportunity given for the ultimate judicial determination of the liability is adequate." Id., at 596-597.
Thus today's decision does not merely discard established precedents regarding excise taxes, but deals at least a glancing blow to the authority of the Government to collect income tax delinquencies by summary proceedings.
II
The Court attempts to justify the result it reaches by expansive readings of Fuentes v. Shevin, 407 U. S. 67 (1972), and Connecticut v. Doehr, 501 U. S. 1 (1991). In Fuentes, the Court struck down state replevin procedures, finding that they served no important state interest that might justify the summary proceedings. 407 U. S., at 96. Specifically, the Court noted that the tension between the private buyer's use of the property pending final judgment and the private seller's interest in preventing further use and deterioration of his security tipped the balance in favor of a prior hearing in certain replevin situations. "[The provisions] allow summary seizure of a person's possessions when no more than private gain is directly at stake." Id., at 92. Cf. Mitchell v. W. T. Grant Co., 416 U. S. 600 (1974) (upholding Louisiana sequestration statute that provided immediate postdeprivation hearing along with the option of damages).
The Court in Fuentes also was careful to point out the limited situations in which seizure before hearing was constitutionally permissible, and included among them "summary
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