The First Agricultural National Bank of Berkshire County v. State Tax Commission case in 1967 revolved around the issue of whether a state could tax federal bank shares without violating the Supremacy Clause of the U.S. Constitution, which establishes that federal law takes precedence over state laws and regulations. The Supreme Court ruled in favor of Massachusetts' right to impose such taxes on national banks operating within its jurisdiction, stating that it did not infracft upon any constitutional provisions or interfere with federal operations. The court held that as long as states apply their taxing power uniformly and do not discriminate against federally chartered institutions, they are within their rights to levy taxes on these entities.

In the dissenting opinion for First Agricultural National Bank of Berkshire County v. State Tax Commission, Justice Harlan disagreed with the majority's interpretation of federal law and its application to state taxation. He argued that Massachusetts' tax on national banks did not violate federal law because it was applied uniformly to all financial institutions in the state, including both national and state-chartered banks. According to Justice Harlan, this uniformity meant that there was no discrimination against national banks as prohibited by federal statute. Furthermore, he contended that Congress had intended for states to have broad authority over their own taxation policies when they passed legislation regulating taxes on national banks. Therefore, he believed that Massachusetts' tax should be upheld as a valid exercise of this authority.