In the case of Baltimore National Bank v. State Tax Commission of Maryland, the U.S Supreme Court ruled in favor of the State Tax Commission. The bank had challenged a tax imposed by Maryland on shares held by its shareholders, arguing that it was unconstitutional as it violated both due process and equal protection clauses under Fourteenth Amendment. However, the court upheld this taxation method stating that there was no violation since banks were not being taxed directly but rather through their shareholders' stock ownership which is considered personal property within state jurisdiction for tax purposes. Furthermore, they found no discrimination or unequal treatment because all national banks and corporations in Maryland were subjected to similar taxes based on share value.

In the dissenting opinion for Baltimore National Bank v. State Tax Commission of Maryland, it was argued that the majority's decision to uphold a tax on national banks imposed by the state of Maryland was inconsistent with previous rulings and interpretations of federal law. The dissenting justices believed that such taxation infringed upon federal sovereignty and violated principles established in McCulloch v. Maryland (1819). They contended that this case represented an overreach by states into areas reserved for federal jurisdiction, specifically banking regulation. Furthermore, they expressed concern about potential negative impacts on national banks due to differing tax laws across states which could create an uneven playing field between them and state-chartered institutions within their respective jurisdictions.