d interest thereon by deduction from any claim
under the policy, such credit is not taxable to the foreign insurance
company.[580] Premiums due from residents on which an extension has been
granted by foreign companies also are credits on which the latter may be
taxed by the State of the debtor's domicile;[581] and the mere fact that
the insurers charge these premiums to local agents and give no credit
directly to policyholders does not enable them to escape this tax.[582]
PROCEDURE IN TAXATION
In General
Exactly what due process requires in the assessment and collection of
general taxes has never been decided by the Supreme Court. While it was
held that "notice to the owner at some stage of the proceedings, as well
as an opportunity to defend, is essential" for imposition of special
taxes, it has also ruled that laws for assessment and collection of
general taxes stand upon a different footing and are to be construed
with the utmost liberality, even to the extent of acknowledging that no
notice whatever is necessary.[583] Due process of law as applied to
taxation does not mean judicial process;[584] neither does it require
the same kind of notice as is required in a suit at law, or even in
proceedings for taking private property under the power of eminent
domain.[585] If a taxpayer is given an opportunity to test the validity
of a tax at any time before it is final, whether the proceedings for
review take place before a board having a quasi-judicial character, or
before a tribunal provided by the State for the purpose of determining
such questions, due process of law is not denied.[586]
Notice and Hearing in Relation to General Taxes
"Of the different kinds of taxes which the State may impose, there is a
vast number of which, from their nature, no notice can be given to the
taxpayer, nor would notice be of any possible advantage to him, such as
poll taxes, license taxes (not dependent upon the extent of his
business), and generally, specific taxes on things, or persons, or
occupations. In such cases the legislature, in authorizing the tax,
fixes its amount, and that is the end of the matter. If the tax be not
paid, the property of the delinquent may be sold, and he be thus
deprived of his property. Yet there can be no question, that the
proceeding is due process of law, as there is no inquiry into the weight
of evidence, or other element of a judicial nature, and nothing could be
changed by hearing the
|