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Bank of California v. Richardson, 248 U.S. 476 (1919)

Bank of California v. Richardson

No. 262

Submitted October 14, 1918

Decided January 27, 1919

248 U.S. 476


The extent to which the states may tax the property or the shares of national banks is determined exclusively by § 5219 of the Revised Statutes. P. 248 U. S. 482.

The object of the section is to avoid withdrawing the financial resources of national banks from the reach of state taxation, and at the same time to protect the banks as federal agencies from state interference. It therefore, with certain restrictions, permits the shares of the bank to be taxed to the shareholders, and, in that aspect treats the ultimate beneficial interest of the bank and the shareholders as one, subject to but one taxation and by that method only. P. 248 U. S. 483.

It follows, (1) that the interest represented by shares of a state bank,

Page 248 U. S. 477

when held by a national bank, can be reached only by a tax upon the shares of the latter, and is not taxable to the national bank itself, and (2) that shares of a national bank, when held by another national bank, are taxable only to the latter as shareholder, and are not to be included in valuing the share of the latter when taxing its shareholders. Pp. 248 U. S. 484-486.

175 Cal. 813 reversed.

The case is stated in the opinion.

Page 248 U. S. 480

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