First National Bank of Atlanta, As Successor in Interest to First National Bank of Cartersville, Georgia v. Bartow County Board of Tax Assessors et al. (470 U.S. 583)
U.S. Supreme Court · decided March 19, 1985 · Supreme Court Database (Spaeth)
- Citation
- 470 U.S. 583 · 105 S. Ct. 1516
- Decided
- March 19, 1985
- Term
- October Term 1984
- Vote
- 9–0
- Majority author
- Justice Blackmun
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Blackmun delivered the opinion of the Court. Two Terms ago, this Court, by a 6-2 vote, ruled that Rev. Stat. §3701, as amended, 31U. S. C. §742 (1976 ed.), prohibited a State from imposing on bank shares a property tax computed on the basis of the bank’s net worth without deduction for tax-exempt United States obligations held by the bank. American Bank & Trust Co. v. Dallas County, 463 U. S. 855 (1983). Section 3701 at that time provided: “[A]ll stocks, bonds, Treasury notes, and other obligations of the United States, shall be exempt from taxation by or under State or municipal or local authority. This exemption extends to every form of taxation that would require that either the obligations or the interest thereon, or both, be considered, directly or indirectly, in the computation of the tax, except nondiscriminatory franchise or other nonproperty taxes in lieu thereof imposed on corporations and except estate taxes or inheritance taxes.” In this case, we address a question left open in American Bank, see 463 U. S., at 865, n. 10: must a State, for property tax purposes, allow a bank to deduct from net worth the full value of tax-exempt United States obligations it holds, or is § 3701 satisfied by a limited deduction that excludes from net worth only that portion of the federal obligations properly attributable to assets rather than to liabilities? HH Effective…
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