payment of fixed or variable sums of money are other sanctions which have been recognized as enforceable by civil proceedings since the original revenue law of 1789. In spite of their comparative severity, such sanctions have been upheld against the contention that they are essentially criminal and subject to the procedural rules governing criminal prosecutions. Id. at 399-400, 58 S.Ct. at 633 (citations omitted) (emphasis added). Nearly thirty-five years after Helvering was decided, the Supreme Court reaffirmed — in the context of a forfeiture proceeding — the analytic approach that the Court developed in Helvering for determining whether a statute is “essentially criminal.” See One Lot Emerald Cut Stones v. United States, 409 U.S. 232, 93 S.Ct. 489, 34 L.Ed.2d 438 (1972) (per curiam) (<HOLDING>). Most recently, while again reaffirming
holding that a proceeding to forfeit imported merchandise not included in a declaration was civil not criminal for purposes of the double jeopardy clause holding that double jeopardy clause did not apply to forfeiture proceeding before the court holding that a delinquency proceeding places a juvenile in jeopardy for purposes of the double jeopardy clause holding that civil forfeitures are neither punishment nor criminal for purposes of the double jeopardy clause holding that the dismissal of criminal charges for evidentiary insufficiency is an acquittal for purposes of the double jeopardy clause