In the case of Cary, Collector v. The Savings Union, the Supreme Court of the United States was asked to decide whether the federal government had the authority to tax a state-chartered savings union. The Savings Union argued that it was exempt from taxation under the terms of its charter. The Collector argued that the federal government had the authority to tax the Savings Union under the Constitution. The Supreme Court held that the federal government did have the authority to tax the Savings Union. The Court reasoned that the Constitution gave the federal government the power to tax all persons, corporations, and entities, regardless of their state-chartered status. The Court further held that the Savings Union was not exempt from taxation under the terms of its charter, as the charter did not explicitly exempt the Savings Union from taxation. The Court's decision established that the federal government had the authority to tax state-chartered entities, and that the terms of the charter did not exempt the Savings Union from taxation. This decision has been cited in numerous subsequent cases involving the taxation of state-chartered entities.

In Cary, Collector v. The Savings Union, the Supreme Court was tasked with determining whether or not a tax imposed by Congress on savings banks was constitutional. The majority opinion held that the tax did not violate any of the provisions of the Constitution and thus could be enforced. However, Justice Field dissented from this decision arguing that it violated Article I Section 8 Clause 1 which grants Congress power to lay taxes only for public purposes and does not allow them to impose taxes for private gain or purpose. He further argued that since there is no evidence showing how this particular tax would benefit society as a whole then it should be deemed unconstitutional because it serves no public purpose but rather benefits private interests such as those who own stock in savings banks.