taxpayer. No right of his is, therefore, invaded.
Thus, if the tax on animals be a fixed sum per head, or on articles a
fixed sum per yard, or bushel, or gallon, there is nothing the owner can
do which can affect the amount to be collected from him. So, if a person
wishes a license to do business of a particular kind, or at a particular
place, such as keeping a hotel or a restaurant, or selling liquors, or
cigars, or clothes, he has only to pay the amount required by law and go
into the business. There is no need in such cases for notice or hearing.
So, also, if taxes are imposed in the shape of licenses for privileges,
such as those on foreign corporations for doing business in the State,
or on domestic corporations for franchises, if the parties desire the
privilege, they have only to pay the amount required. In such cases
there is no necessity for notice or hearing. The amount of the tax would
not be changed by it."[587]

Notice and Hearing in Relation to Assessments

"But where a tax is levied on property not specifically, but according
to its value, to be ascertained by assessors appointed for that purpose
upon such evidence as they may obtain, a different principle comes in.
The officers in estimating the value act judicially; and in most of the
States provision is made for the correction of errors committed by them,
through boards of revision or equalization, sitting at designated
periods provided by law to hear complaints respecting the justice of the
assessments. The law in prescribing the time when such complaints will
be heard, gives all the notice required, and the proceeding by which the
valuation is determined, though it may be followed, if the tax be not
paid, by a sale of the delinquent's property, is due process of
law."[588]

Nevertheless, it has never been considered necessary to the validity of
a tax that the party charged shall have been present, or had an
opportunity to be present, in some tribunal when he was assessed.[589]
Where a tax board has its time of sitting fixed by law and where its
sessions are not secret, no obstacle prevents the appearance of any one
before it to assert a right or redress a wrong; and in the business of
assessing taxes, this is all that can be reasonably asked.[590] Nor is
there any constitutional command that notice of an assessment as well as
an opportunity to contest it be given in advance of the assessment. It
is enough that all available defenses may be presen