Bank for Savings v. The Collector was a case heard by the United States Supreme Court in 1865. At issue was whether or not the Bank of Savings, located in New York City, had to pay taxes on certain bonds it held as part of its assets. The bank argued that these bonds were exempt from taxation under an act passed by Congress in 1864 which exempted state and municipal securities from taxation. However, the Collector argued that this exemption did not apply to banks such as Bank for Savings because they were private institutions and thus could not be considered “state” or “municipal” entities within the meaning of the law. After considering both sides' arguments, the court ruled unanimously in favor of Bank for Savings and found that it was indeed exempt from paying taxes on those particular bonds due to their status as state-issued securities according to Congressional legislation at that time.

In Bank for Savings v. The Collector, the Supreme Court was tasked with determining whether a state-chartered bank could be taxed by the federal government. The majority opinion held that such taxation was constitutional and within Congress’s power to tax under Article I of the Constitution. However, Justice Field dissented from this decision on two grounds: firstly, he argued that it violated states' rights as guaranteed in Article IV; secondly, he argued that it would lead to double taxation of banks since they were already subject to state taxes. He concluded his dissent by stating that if Congress had intended for these institutions to be taxed federally then they should have been explicitly mentioned in either Article I or IV instead of leaving them open to interpretation and potential abuse through overreaching interpretations like this one which allowed federal taxation without explicit authorization from either article.