The U.S. Supreme Court case First Bank Stock Corp. v. Minnesota in 1936 revolved around the constitutionality of a state tax imposed on national banks by Minnesota, which was challenged by First Bank Stock Corporation as discriminatory and unconstitutional under both federal law and the Fourteenth Amendment's Equal Protection Clause. The bank argued that it was unfairly targeted because other corporations were not subject to this tax, creating an unequal burden on national banks operating within the state. However, the court ruled in favor of Minnesota, upholding its right to impose such taxes on national banks operating within its jurisdiction. It found no violation of either federal law or constitutional rights since states have broad powers over taxation matters unless expressly prohibited by Congress or Constitution itself. In essence, this ruling affirmed that while National Banks are federally created entities they are also subject to certain forms of state taxation without violating their equal protection rights under the Fourteenth Amendment.

In the dissenting opinion for the case of First Bank Stock Corp. v. Minnesota, Justice Cardozo disagreed with the majority's ruling that a state tax on national bank shares was unconstitutional because it included in its calculation assets exempt from state taxation under federal law (U.S. government securities). He argued that this interpretation contradicted previous court decisions and undermined states' rights to levy taxes as they saw fit within their jurisdiction. According to him, if a corporation chooses to invest in U.S government bonds knowing they are not subject to direct taxation by states, it should also accept any indirect consequences of such investment choices including higher share value leading to increased taxes on those shares. Furthermore, he pointed out that there is no provision in federal law explicitly prohibiting states from considering federally-exempt assets when calculating taxes on other property or income sources related thereto.