I think you're relatively safe screwing around to avoid making a starter for a low-gravity beer but I think when it comes to high-gravity beers there is no reason to be a slacker. The beer is bound to take at least several months to ferment and condition, and already cost more than average for the amount of ingredients that go into it. If you're going to all the extra trouble to brew something high-gravity, you might as well spend a little time and make a proper starter - it's likely to maximize the quality of your beer, and helps avoid likely stalled-fermentation headaches.
Besides, mrmalty's pitching rate calculator claims you should be using just over 3 packs of liquid yeast if you skip a starter, and that's assuming nearly 100% viability - if your yeast is even a MONTH old it calls for 4 packs, and at 2 months old it calls for nearly 6 packs. If you got 2 packs of brand-new packaged-yesterday liquid yeast I think you might be somewhat safe, but that's not likely to happen. Chances are your yeast will be way less than 100% viable and you'll end up WAY underpitching as a result.