Summary

Portrait of James Clark McReynolds James Clark McReynolds First National Bank of Gulfport v…

Ct. 537, 43 L. Ed. 850, a tax levied upon a corporation measured by the value of its shares is not equivalent to one upon the shareholders in respect of their shares.
Where the validity of an assessment by officers of the state is properly challenged, and the matter comes here, this court must determine the effect of the thing actually done. What might have been done under the local statute is not controlling. We think it clear that the assessment in the present case was against the corporation and beyond the power of the state definitely delimited by section 5219.
Source: Wikisource

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