Earl Warren

“ The extent of the mineral estates owned by federal land banks is considerable: petitioner owns an interest in approximately 283,000 acres; all land banks own an interest in 9,900,000 acres. [27]
Since there are no infirmities in the holding of the mineral estate by the petitioner, there is no basis for implying that Congress did not intend § 931 to provide immunity in this case. As an express immunity has been conferred, there is no need to consider whether the doctrine of implied immunity applies. ”

“ A political subdivision of a State has levied a personal property tax on a federal instrumentality despite a claim of immunity by virtue of a federal statute.
Petitioner, the Federal Land Bank of Wichita, acquired a mortgage on realty in Kiowa County, Kansas, in the course of its business as a federal instrumentality duly organized under the Federal Farm Loan Act. [1] Upon default, foreclosure, purchase at a sheriff's sale, and confirmation, petitioner became the owner of the land. ”

“ Analytically, the power given to the Farm Credit Administration by § 781 Fourth (b) is a licensing power, [23] not a rulemaking, an adjudicating, or an investigating power. The regulation states that federal land banks have permission to retain mineral interests longer than five years. This is an exercise of the power to license, not a delegation of it.
The second ground for invalidating the permission given by the Farm Credit Administration was that permission could not be given unless the holding of the land was necessary to recoup the loss on the defaulted mortgage. ”