MR. JUSTICE MARSHALL delivered the opinion of the Court.These companion cases involve two taxpayers whose taxable years were terminated by the Internal Revenue Service (IRS) prior to their normal expiration date pursuant to the jeopardy termination provisions of § 6851(a)(1) of the Internal Revenue Code of 1954 (Code), 26 U.S.C. § 6851(a)(1). [Footnote 1]  Section 6851(a)(1) allows the IRS immediately to terminate a taxpayer's taxable period when it finds that the taxpayer intends to do any act tending to prejudice or render ineffectual the collection of his income tax for the current or preceding taxable Page 423 U. S. 164 year.  Upon termination, the tax is immediately owing, and, after notice, the IRS may, and usually does, levy upon the taxpayer's property under § 6331(a) of the Code, 26 U.S.C. § 6331(a), to assure payment.We must decide whether the IRS, when assessing and collecting the unreported tax due after the termination of a taxpayer's taxable period, must follow the procedures mandated by § 6861 et seq. of the Code, 26 U.S.C. § 6861 et seq., for the assessment and collection of a deficiency whose collection is in jeopardy. [Footnote 2]  The answer, as we shall see, depends on whether the unreported tax due upon such a termination is a "deficiency" as defined in § 6211(a) of the Code, 26 U.S.C. § 6211(a) (1970 ed. and Supp. IV).  The Government argues that the tax liability that arises after a § 6851 termination cannot be a "deficiency," and that the procedures for the assessment and collection of deficiencies in jeopardy are therefore inapplicable.  We reject this argument.  We agree with the taxpayers that any tax owing, but unreported, after a § 6851 termination is a deficiency, and that the assessment of that deficiency is subject to the provisions of § 6861 et seq.  We reverse in No. 73-1808 and affirm in No. 74-75.IA. No. 73-1808, Laing v. United States.  Petitioner James Burnett McKay Laing is a citizen of New Zealand.  Page 423 U. S. 165 He entered the United States from Canada on a temporary visitor's visa on May 31, 1972.  On the following June 24, Mr. Laing and two companions sought to enter Canada from Vermont, but were refused entry by Canadian officials.  As they turned back, they were detained by United States customs authorities at Derby, Vt.  Upon a search of the vehicle in which the three were traveling, the customs officers discovered in the engine compartment a suitcase containing more than $300,000 in United States currency.  The IRS District Director found that petitioner Laing and his companions were in the process of placing assets beyond the reach of the Government by removing them from the United States, thereby tending to prejudice or render ineffectual the collection of their income tax. [Footnote 3]  He declared the taxable periods of petitioner and his companions immediately terminated under § 6851(a).  An assessment of $310,000 against each was orally asserted for the period from January 1 through June 24, 1972.  The assessment against Mr. Laing was subsequently abated to the amount of $195,985.55 when a formal letter notice of termination and demand for payment and the filing of a return were sent.  Mr. Laing received no deficiency notice under § 6861(b) and no specific information about how the amount of the tax was determined. [Footnote 4]After Mr. Laing and his companions refused to pay the tax, the IRS seized the currency that had been found Page 423 U. S. 166 in the vehicle.  A portion thereof was applied to the tax assessed against Mr. Laing. [Footnote 5]On July 15, petitioner filed suit against the United States, the Commissioner of Internal Revenue, the District Director, and the Chief of the Collection Division, District of Vermont, in the United States District Court for the District of Vermont.  He asserted the absence of a notice of deficiency, which he claimed was required under § 6861(b), and he challenged as violative of due process both the provisions of the levy and distraint statute, § 6331(a), and the actions of the IRS in seizing and retaining the currency "without any finding of a substantial or probable nexus between that money and taxable income."  App. in No. 73-1808, p. 20. [Footnote 6]The District Court, relying on its controlling court's decision in Irving v. Gray, 479 F.2d 20 (CA2 1973), held that a notice of deficiency is not required when a taxable period is terminated pursuant to § 6851(a)(1), and dismissed the suit as prohibited by the Federal Anti-Injunction Act, § 7421(a) of the Code, 26 U.S.C. § 7421(a), and as within the plain wording of the exception to the Declaratory Judgment Act, 28 U.S.C. § 2201, for a controversy with respect to federal taxes.  364 F. Supp. 469 (1973).Adhering to its earlier ruling in Irving, the Second Circuit affirmed per curiam.  496 F.2d 853 (1974).  It expressly declined to follow the Sixth Circuit's decision in Rambo v. United States, 492 F.2d 1060 (1974). [Footnote 7]  These rulings of the Second Circuit, and one of the Page 423 U. S. 167 Seventh Circuit, Williamson v. United States, 31 A.F.T.R.2d 73-800 (1971), appeared to be in conflict with holdings by other Courts of Appeals, Rambo v. United States, supra; Hall v. United States, 493 F.2d 1211 (CA6 1974); and Clark v. Campbell, 501 F.2d 108 (CA5 1974), [Footnote 8] Suggesting that the conflict was irreconcilable and noting that some 70 pending cases in the federal courts depended on its resolution, the Solicitor General did not oppose Mr. Laing's petition for certiorari.  We granted certiorari to resolve the conflict. [Footnote 9]  419 U.S. 824 (1974).B. No. 74-75, United States v. Hall.  Respondent Elizabeth Jane Hall is a resident of Shelbyville, Ky.  After the arrest of her husband in Texas on drug-related charges, Kentucky state troopers obtained a warrant and searched respondent's home on January 31, 1973.  They found controlled substances there.  The next day, the Acting District Director notified respondent Hall by letter that he found her "involved in illicit drug activities, thereby tending to prejudice or render ineffectual collection of income tax for the period 1-1-73 thru 1-30-73."  App. in No. 74-75, p. 11.  Citing § 6851, the Acting Director declared respondent's taxable period for the first 30 days of 1973 "immediately terminated" and her income tax for that period "immediately due and payable."  Ibid.  He further informed respondent that a tax in the amount of $52,680.25 for the period "will be immediately assessed" and that "[d]emand for immediate payment of the full amount of this tax is hereby made."  Ibid.  A return for the terminated period, pursuant to § 443(a)(3) of the Code, 26 U.S.C. § 443(a)(3), Page 423 U. S. 168 was requested, but not filed.  The formal assessment was made on February 1.  As was the case with Mr. Laing, Mrs. Hall received no deficiency notice under § 6861(b) and no specific information about how the amount of the tax had been determined.Respondent was unable to pay the tax so assessed.  Therefore, the IRS, acting pursuant to § 6331, levied upon and seized respondent's 1970 Volkswagen and offered it for sale. [Footnote 10]Respondent Hall instituted suit on February 13 in the United States District Court for the Western District of Kentucky, seeking injunctive relief and compensatory and punitive damages.  The court issued an order temporarily restraining the IRS from selling the automobile and from seizing any more of respondent's property.  Thereafter, relying upon Schreck v. United States, 301 F. Supp. 1265 (Md.1969), the court held that the Federal Anti-Injunction Act, § 7421(a), was inapplicable because of the IRS's failure to follow the procedures of § 6861 et seq.  The court ordered the return of respondent's automobile upon her posting a bond in the amount of its fair market value. [Footnote 11]  It issued a preliminary injunction restraining the defendants (the United States, the Acting District Director, the Group Supervisor of Internal Revenue, and a lieutenant of the Kentucky State Police)"from harassing or intimidating [respondent] in any manner including but not limited to trespassing on, seizing or levying upon any of her property of whatever nature, be it rental property or not."Pet. for Cert. in No. 74-75, p. 5a. Page 423 U. S. 169On appeal, the United States Court of Appeals for the Sixth Circuit affirmed per curiam, 493 F.2d 1211 (1974), relying upon its opinion and decision in Rambo v. United States, supra, decided one month earlier.  In Rambo, the court had held that the failure of the IRS to issue a deficiency notice for a terminated taxable period, and the consequent unavailability of a remedy in the United States Tax Court, entitled the taxpayer to injunctive relief.  Because of the conflict, indicated above, we also granted certiorari in Mrs. Hall's case.  419 U.S. 824 (1974).IIIn these cases, the taxpayers seek the protection of certain procedural safeguards that the Government claims were not intended to apply to jeopardy terminations.  Specifically, the taxpayers argue that the procedures mandated by § 6861 et seq. for assessing and collecting deficiencies whose collection is in jeopardy also govern assessments of taxes owing, but not reported, after the termination of a taxpayer's taxable period under § 6851.  Resolution of this claim requires analysis of the interplay between these two basic jeopardy provisions -- § 6851, the jeopardy termination provision, and § 6861, the jeopardy assessment provision.The initial workings of the jeopardy termination provision, which essentially permits the shortening of a taxable year, are not in dispute.  When the District Director determines that the conditions of  6851(a) are met -- generally, that the taxpayer is preparing to do something that will endanger the collection of his taxes [Footnote 12] -- the District Director may declare the taxpayer's Page 423 U. S. 170 current tax year terminated.  The tax for the shortened period and any unpaid tax for the preceding year become due and payable immediately, § 6851(a), and the taxpayer must file a return for the shortened year. § 443(a)(3).The disagreement between the taxpayers and the Government focuses on the applicability of the jeopardy assessment procedures of § 6861 et seq. to the assessment [Footnote 13] and collection of taxes that become due upon a § 6851 termination.  Section 6861(a) provides for the immediate assessment of a deficiency, as defined in § 6211(a), whenever the assessment or collection of the deficiency would be "jeopardized by delay."  By allowing an immediate assessment, § 6861(a) provides an exception to the general rule barring an assessment until the taxpayer has been sent a notice of deficiency and has been afforded an opportunity to seek resolution of his tax liability in the Tax Court. [Footnote 14]  Certain procedural safeguards are provided, however, to the taxpayer whose deficiency is assessed Page 423 U. S. 171 immediately under § 6861(a).  Within 60 days after the jeopardy assessment, the District Director must send the taxpayer a notice of deficiency, § 6861(b), which enables the taxpayer to file a petition with the Tax Court for a redetermination of the deficiency, 26 U.S.C. § 6213(a) (1970 ed., Supp. IV).  The taxpayer can stay the collection of the amount assessed by posting an equivalent bond, § 6863(a).  Any property seized for the collection of the tax cannot be sod until a notice of deficiency is issued and the taxpayer is afforded an opportunity to file a petition in the Tax Court.  If the taxpayer does seek a redetermination of the deficiency in the Tax Court, the prohibition against sale extends until the Tax Court decision becomes final.  § 6863(b)(3)(A). [Footnote 15]The taxpayers view the provisions of § 6861 et seq. as complementary to those of § 6851.  They contend that, to the extent the tax owing upon a jeopardy termination has not been reported, it is a "deficiency" as that term is defined in § 6211(a) and used in § 6861(a), and that the deficiency, being of necessity one whose assessment or collection is in jeopardy, [Footnote 16] must be assessed and collected in accordance with the procedures of § 6861 et seq.Under the Government's view, on the other hand, §§ 6851 and 6861 are aimed at distinct problems, and have no bearing on each other.  "Section 6851," according to the Government,"advances the date when Page 423 U. S. 172 taxes are due and payable, while Section 6861 advances the time for collection of taxes which are already overdue [i.e., already owing for a prior, normally expiring taxable year]."Brief for United States 10.  The validity of this distinction rests on the Government's claim that a deficiency can arise only with respect to a nonterminated taxable year, so that no deficiency can be created by a § 6851 termination.  If there is no deficiency to assess, of course, the provisions of § 6861 et seq. cannot apply.Thus, under the Government's reading of the Code, the procedures for assessment and collection of a tax owing, but not reported, after the termination of a taxable period are not governed by § 6861 et seq. [Footnote 17]  The Government argues that, with the single exception of the bond provision of § 6851(e), the taxpayer's only remedy upon a jeopardy termination is to pay the tax, file for a refund, and, if the refund is refused, bring suit in the district Page 423 U. S. 173 court or the Court of Claims.  See 28 U.S.C. § 1346(a)(1).  Since the IRS has up to six months to act on a request for a refund, the taxpayer, under the Government's theory, may have to wait up to half a year before gaining access to any judicial forum.  See 26 U.S.C. §§ 6532(a), 7422(a) (1970 ed. and Supp. IV).The Government does not seriously challenge the taxpayers' conclusion that, if the termination of their taxable periods created a deficiency whose assessment or collection was in jeopardy, the assessments and collections in these cases should have been pursuant to the procedures of § 6861 et seq.  The question, then, is whether the tax owing, but not reported, upon a jeopardy termination is a deficiency within the meaning of § 6211(a).IIIIn essence, a deficiency as defined in the Code is the amount of tax imposed less any amount that may have been reported by the taxpayer on his return. [Footnote 18]  § 6211(a).  Page 423 U. S. 174 Where there has been no tax return filed, the deficiency is the amount of tax due.  Treas.Reg. § 301.6211-1(a), 26 CFR § 301.6211-1(a)(1975).  As we have seen, upon terminating a taxpayer's taxable year under § 6851, the District Director makes a demand for the payment of the unpaid tax for the terminated period and for the preceding taxable year.  The taxpayer is then required to file a return for the truncated taxable year.  § 443(a)(3).  The amount due, of course, must be determined according to ordinary tax principles, as applied to the abbreviated reporting period.  The amount properly assessed upon a § 6851 termination is thus the amount of tax imposed under the Code for the preceding year and the terminated short year, less any amount that may already have been paid.  To the extent this sum has not been reported by the taxpayer on a return, it fits precisely the statutory definition of a deficiency. [Footnote 19]The Government resists this conclusion by reading the definition of "deficiency" restrictively to include only those taxes due at the end of a full taxable year when a return has been or should have been made.  It argues that a "deficiency" cannot be determined before the close of a taxable year.  Of course, we agree with the Government Page 423 U. S. 175 that a deficiency does not arise until the tax is actually due and the taxable year is complete.  The fact is, however, that, under § 6851 the tax is due immediately upon termination.  Moreover, upon a § 6851 termination, the taxpayer's taxable year has come to a close.  See Sanzogmo v. Commissioner, 60 T.C. 321, 325 (1973). [Footnote 20]  Section 441(b)(3) defines as a "taxable year" the terminated taxable period on which a return is due under § 443(a)(3).  See also § 7701(a) (23).  Under the statutory definition of § 6211(a), the tax owing and unreported after a Jeopardy termination, which, in these cases and in most § 6851 terminations, is the full tax due, is clearly a deficiency.  We see nothing in the definition to suggest that a deficiency can arise only at the conclusion of a 12-month taxable year; it is sufficient that the taxable period in question has come to an end and the tax in question is due and unreported. [Footnote 21] Page 423 U. S. 176Besides conflicting with the plain language of the Code provisions directly before us, the Government's position in these cases would, for no discernible purpose, isolate the taxpayer subjected to a jeopardy termination from most other income taxpayers.  If the unreported tax due after a jeopardy termination is not a deficiency, the IRS need not issue the taxpayer a deficiency notice and accord him access to the Tax Court for a redetermination of his tax.  Denial of an opportunity to litigate in the Tax Court is out of keeping with the thrust of the Code, which generally allows income tax payers access to that court.  Where exceptions are intended, the Code is explicit on the matter.  See, e.g., § 6871(b).  Denying a Tax Court forum to a particular class of taxpayers is sufficiently anomalous that an intention to do so should not be imputed to Congress when the statute does not expressly so provide.  This is particularly so in view of the Government's concession that the jeopardy assessment procedures of § 6861 et seq. are sufficient to protect its interests, and that providing taxpayers with the Page 423 U. S. 177 limited protections of those procedures would not impair the collection of the revenues. [Footnote 22]IVWhile the plain language of the provisions at issue here and their place in the legislative scheme suggest that the unreported tax due upon a § 6851 termination is a deficiency, and that the deficiency, its collection being in jeopardy, must be assessed and collected according to the procedures of § 6861 et seq., the Government attempts to undercut this conclusion by pointing to the legislative history of the several provisions at issue in this case.  We are unpersuaded.  The jeopardy assessment and jeopardy termination provisions have long been treated in a closely parallel fashion, and nothing that the Government points to in the early codifications suggests the contrary.As the Government points out, the Revenue Act of 1918 (1918 Act) contained a termination provision, § 250(g), 40 Stat. 1084, that was very similar to the present § 6851.  Under the 1918 statute, all assessments were made under the authority of Rev.Stat. § 3182, [Footnote 23] and the taxpayer could attack an assessment only by paying the amount claimed and bringing suit for a refund in district court.  Since there was no way for the taxpayer to contest assessments prior to payment, the Government had no need for any expedited jeopardy assessment procedure Page 423 U. S. 178 such as is now authorized in § 6861. [Footnote 24]  When a termination was made under § 250(g), the tax assessment and collection thus proceeded exactly as in any other case -- the taxpayer had to pay first and litigate later.In the Revenue Act of 1921 (1921 Act), 42 Stat. 227, Congress added both a special procedure for prepayment challenges to assessments and an exception to that procedure.  The special procedure made available, under certain circumstances, a limited administrative remedy within the Bureau of Internal Revenue (predecessor to the IRS) by which taxpayers could question assessments before paying the taxes assessed.  § 250(d) of the 1921 Act, 42 Stat. 266.  The Commissioner could, however, Page 423 U. S. 179 pretermit that procedure if he believed that collection of the revenues might be jeopardized by delay.  This exception, contained in a proviso to § 250(d), was the precursor of § 6861.  Since the proviso limited the availability of the administrative remedy to cases where collection of the taxes due would not be "jeopardized by such delay," the remedy was necessarily inapplicable to cases in which a § 250(g) termination was made.  As of 1921, then, the nascent prepayment remedy was available to ordinary taxpayers but not to taxpayers in either jeopardy situation -- where the tax year had been terminated pursuant to § 250(g), or where the full tax year had run and the Commissioner had determined that the collection of the tax would be jeopardized under the proviso to § 250(d).The Government, however, relies heavily on the 1921 Act, claiming that "[t]he key to an understanding of the term deficiency' lies" therein.  Brief for United States 42.  It relies on a reference to the term "deficiency" in § 250(b), which set out the procedure for handling underpayments after returns had been filed:"If the amount already paid is less than that which should have been paid, the difference, to the extent not covered by any credits due to the taxpayer under section 252 (hereinafter called 'deficiency') . . . shall be paid upon notice and demand by the collector."40 Stat. 265.  This "hereinafter" reference was permanently eliminated when the Act was revised in the Revenue Act of 1924 (1924 Act) and the word "deficiency" precisely defined -- in much the same way as it is today.  Nonetheless, the Government persists in viewing the reference in the 1921 Act as an authoritative definition of "deficiency."  Since the reference related only to money owed after a return had been filed and examined, the Government Page 423 U. S. 180 argues that Congress in 1921 did not consider the amount assessed pursuant to a jeopardy termination -- which often must be assessed before a return is filed -- to be a "deficiency."  This supposed limitation in the 1921 Act continues, in the Government's view, to this day.  We disagree with the Government's analysis.To understand the use of the word "deficiency" in the 1921 Act, it is necessary to begin with the 1918 Act, where the term first appeared.  In the 1918 statute, the term was not formally defined, but appeared in various provisions dealing with underpayments and overpayments of tax, referring to the difference between the amount due and the amount already paid.  "Deficiency" was used synonymously with the word "understatement," and it is clear from the context that neither word was being used as a term of art. In the 1921 Act, the 1918 language was left largely unchanged, except that, after the reference to the difference between the amount paid and the amount due, Congress added the parenthetical expression "(hereinafter called deficiency')," and, from that point on, replaced all references to "understatement" with the word "deficiency."  From the context, it is evident that the "hereinafter" parenthetical term was not intended as a restrictive definition of deficiency, but merely as an indication that, throughout the subsection, the word would be used as shorthand for the difference between the amount paid and the amount that should have been paid. [Footnote 25]  We thus find nothing in the informal use of the term "deficiency" in the 1921 Act to limit our construction Page 423 U. S. 181 of the precise definition in § 6211(a) of the present Code.In 1924, Congress made a number of important changes in the jeopardy assessment scheme.  The termination section, § 282, 43 Stat. 302, remained basically the same as it had been in § 250(g) of the 1921 Act, but taxpayers' prepayment remedies in the jeopardy assessment provision were substantially altered.  Section 274(a) of the 1924 Act, 43 Stat. 297, provided that, if, "in the case of any taxpayer, the Commissioner determine[d] that there is a deficiency" in the tax imposed by the Act, the Commissioner was required to mail a notice of deficiency to the taxpayer.  Within 60 days of mailing of the notice, and prior to payment of the deficiency, the taxpayer was entitled to file an appeal with the Board of Tax Appeals, an agency independent of the Bureau of Internal Revenue.  The only exception to this statutory provision permitting general access to the Board of Tax Appeals was that for a jeopardy assessment.  The jeopardy assessment provision, § 274(d), permitted the Commissioner to assess and collect a deficiency immediately, bypassing various procedures set out in § 274(a) for the ordinary assessment and collection of deficiencies.  Even in the jeopardy assessment situation, however, the taxpayer could gain access to the Board of Tax Appeals by posting a bond.  § 279(a).Section 273 of the 1924 Act defined "deficiency," much as it is now defined, as the amount by which the tax due exceeds the tax shown on the taxpayer's return, or, "if no return is made by the taxpayer, then the amount by which the tax exceeds the amounts previously assessed (or collected without assessment) as a deficiency."  § 273(2).  In cases in which no return was filed and no amount had previously been assessed or collected, § 273(2) in effect defined a "deficiency" simply as the amount Page 423 U. S. 182 of tax due.  Since § 282 -- the termination provision -- provided that, at the time of termination, the Commissioner would demand"immediate payment of the tax for the taxable period so declared terminated and of the tax for the preceding taxable year or so much of such tax as is unpaid . . . ,"and that the tax demanded would become "immediately due and payable," the tax "due and payable" at the time of the termination notice, to the extent unreported, would appear to fit the definition of "deficiency" in § 273(2).  This being so, the Government's assertion that, under the 1924 Act, § 282 terminations were not subject to the procedures of § 274(d) is incorrect, and much of the force of its argument from the history of the statute is lost.With the amendments made by the Revenue Act of 1926, c. 27, 44 Stat. 9, the statutory provisions relevant to these cases took essentially their present form.  The jurisdiction of the Board of Tax Appeals (subsequently renamed the Tax Court) was broadened, in part by granting taxpayers subjected to jeopardy assessments a means of having their assessment redetermined by the Board without having to post bond as had previously been required.  Under the new jeopardy assessment procedures, the Commissioner could immediately assess the deficiency, but, in addition to a demand for payment, he was required to send a notice of deficiency, § 279(b), which allowed the jeopardy taxpayer immediate access to the Board of Tax Appeals. § 274(a).  As in the 1924 Act, there was no indication that taxpayers subjected to a jeopardy termination would not then be assessed under the jeopardy assessment procedures to the extent a deficiency was owing, and thereby allowed to follow the same route to the Board of Tax Appeals that was available to other jeopardy taxpayers. Page 423 U. S. 183In sum, to the extent that it sheds any light on the question at all, the legislative history seems to help the taxpayers, rather than the Government  In the course of the development of a prepayment remedy and a jeopardy exception to that remedy between 1918 and 1926, taxpayers subjected to jeopardy terminations and those subjected to jeopardy assessments for nonterminated taxable years were consistently treated alike.  In 1921, when the administrative remedy was first created, neither those subjected to a jeopardy assessment for a nonterminated year nor those subjected to a termination could avail themselves of that remedy.  In 1924, those terminated and those subjected to jeopardy assessments for nonterminated years were similarly denied access to the Board of Tax Appeals unless they filed a bond in the amount of the claim.  And in 1926, when the scheme assumed its current form, there was no indication that Congress intended for the first time to treat the two groups separately by granting direct access to the Board of Tax Appeals to those subjected to a jeopardy assessment for a nonterminated year, but denying it to those subjected to an assessment following a jeopardy termination.VBased on the plain language of the statutory provisions, their place in the legislative scheme, and the legislative history, we agree with the taxpayers' reading of the pertinent sections of the Code. [Footnote 26]  Under that reading, the Page 423 U. S. 184 tax owing, but not reported, at the time of a § 6851 termination is a deficiency whose assessment and collection are subject to the procedures of § 6861 et seq.  Section 6861(b) requires a notice of deficiency to be mailed to a taxpayer within 60 days after the jeopardy assessment.  Section 6863 bars the offering for sale of property seized until the taxpayer has had an opportunity to litigate in the Tax Court.  Because the District Director failed to comply with these requirements in these cases, the taxpayers' suits were not barred by the Anti-Injunction Act, [Footnote 27] § 7421(a) of the Code.  The judgment of the Page 423 U. S. 185 United States Court of Appeals for the Sixth Circuit in No. 74-75 is affirmed.  The judgment of the United States Court of Appeals for the Second Circuit in No. 73-1808 is reversed, and the case is remanded to that court for further proceedings consistent with this opinion.It is so ordered
U.S. Supreme CourtLaing v. United States, 423 U.S. 161 (1976)Laing v. United StatesNo. 73-1808Argued January 21, 1975Reargued October 15, 1975Decided January 13, 1976*423 U.S. 161SyllabusThese cases involve two income tax payers whose taxable years were terminated by the Internal Revenue Service (IRS) prior to their normal expiration dates pursuant to the jeopardy termination provisions of § 6851(a)(1) of the Internal Revenue Code of 1954 (Code), which allow the IRS immediately to terminate a taxpayer's taxable period when it finds that the taxpayer intends to commit any act tending to prejudice or render ineffectual the collection of his income tax for the current or. preceding taxable year.  Under § 6851, the tax is due immediately upon termination, and, upon such termination, the taxpayer's taxable year comes to a close.  In each case, after the taxpayer failed to file a return or pay the tax assessed as demanded, the IRS levied upon and seized property of the taxpayer without having sent a notice of deficiency to the taxpayer, a jurisdictional prerequisite to a taxpayer's suit in the Tax Court for redetermination of his tax liability, and without having followed the other procedures mandated by § 6861 et seq. of the Code for the assessment and collection of a deficiency whose collection is in jeopardy.  The Government contends that such procedures are inapplicable to a tax liability arising after a § 6851 termination because such liability is not a "deficiency" within the meaning of § 6211(a) of the Code, where the term is defined as the amount of the tax imposed less any amount that may have been reported by the taxpayer on his return.  In No. 73-1808 the District Court held that a deficiency notice is not required when a taxable period is terminated pursuant to § 6851(a)(1), and dismissed the taxpayer's suit for injunctive and declaratory relief on the ground, inter alia, that it was prohibited by the Anti-Injunction Act, § 7421(a) of the Code, and the Court of Appeals affirmed.  In No. 74-75, the District Court granted the taxpayer injunctive relief, holding that the Anti-Injunction Act was inapplicable because of the IRS's failure to follow the procedures Page 423 U. S. 162 of § 6861 et seq., and the Court of Appeals affirmed.Held:  Based on the plain language of the statutory provisions at issue, their place in the legislative scheme, and their legislative history, the tax owing, but not reported, at the time of a § 6851 termination is a deficiency whose assessment and collection is subject to the procedures of § 6861 et seq., and hence, because the District Director in each case failed to comply with these requirements, the taxpayers' suits were not barred by the Anti-Injunction Act.  Pp.  423 U. S. 169-185.(a) Under the statutory definition of § 6211(a), the tax owing and unreported after a jeopardy termination, which in these cases, as in most § 6851 terminations, is the full tax due, is clearly a deficiency, there being nothing in the definition to suggest that a deficiency can arise only at the conclusion of a 12-month taxable year and it being sufficient that the taxable period in question has come to an end and the tax in question is due and unreported.  Pp.  423 U. S. 173-175.(b) To deny a taxpayer subjected to a jeopardy termination the opportunity to litigate his tax liability in the Tax Court, as would be the case under the Government's view that the unreported tax due after a jeopardy termination is not a deficiency and that, hence, a deficiency notice is not required, would be out of keeping with the thrust of the Code, which generally allows income tax payers access to that court.  Pp.  423 U. S. 176-177.(c) The jeopardy assessment and jeopardy termination provisions have long been treated in a closely parallel fashion, and there is nothing in the early codification of such provisions to suggest the contrary.  Pp.  423 U. S. 177-183.No. 73-1808, 496 F.2d 853, reversed and remanded; No. 74-75, 493 F.2d 1211, affirmed.MARSHALL, J., delivered the opinion of the Court, in which BRENNAN, STEWART, WHITE, and POWELL, JJ., joined.  BRENNAN, J., filed a concurring opinion, post, p.  423 U. S. 185.  BLACKMUN, J., filed a dissenting opinion, in which BURGER, C.J., and REHNQUIST, J., joined, post, p.  423 U. S. 188.  STEVENS, J., took no part in the consideration or decision of the cases. Page 423 U. S. 163