In the Central National Bank v. United States case of 1890, the Supreme Court ruled on a dispute involving taxation and banking. The Central National Bank had issued circulating notes that were subject to a ten percent tax under federal law if they were paid out by state banks or individuals, but not national banks. The bank argued that it should be exempt from this tax because it was acting as an agent for national banks when issuing these notes. However, the court disagreed with this argument and held that only those institutions which Congress has specifically exempted are free from such taxes - in this case, only national banks themselves could claim exemption when paying out their own circulating notes. Therefore, even though the Central National Bank was working on behalf of other national banks, it still had to pay taxes on its issuance of these notes since it wasn't itself a nationally chartered institution.

In the dissenting opinion for Central National Bank v. United States, Justice Lamar argued that the majority's interpretation of the tax law was incorrect. He contended that Congress intended to tax only those banks which were in operation and doing business during a given year, not those which had ceased operations or gone into liquidation before the end of that year. According to him, taxing such non-operational banks would be akin to imposing a penalty rather than collecting revenue as per Congressional intent behind these laws. Furthermore, he disagreed with the majority's view on "double taxation," arguing it should not apply when one bank absorbs another because each entity is separate and distinct under law despite any mergers or acquisitions.