In the 1925 case, First National Bank of Guthrie Center v. Anderson, County Auditor et al., the U.S Supreme Court ruled on a dispute involving taxation of federal bonds. The bank held bonds issued by Federal Land Banks and Joint Stock Land Banks which were exempt from state and local taxes according to federal law. However, Iowa's county auditor included these in assessing the bank's total assets for tax purposes. The court had to decide whether this was permissible under the Constitution’s Supremacy Clause (which establishes that federal law takes precedence over state laws). In its decision, it upheld an earlier ruling (Pittman v Maryland) stating that while states cannot directly tax federally-issued securities or use them as a basis for additional taxation, they can consider such securities when determining a corporation’s overall value for general property tax assessments. Therefore, including federally-issued bonds in calculating a bank's total taxable assets did not violate their exemption from direct taxation.

In the dissenting opinion for the case of First National Bank of Guthrie Center v. Anderson, County Auditor, et al., Justice McReynolds disagreed with the majority's decision that a state law taxing national banks based on their shares was constitutional. He argued that this taxation method violated federal law because it did not treat all shareholders equally and disproportionately burdened out-of-state shareholders. According to him, such unequal treatment contradicted both the spirit and letter of federal legislation designed to ensure uniformity in tax burdens among all bank shareholders regardless of their location or citizenship status. Furthermore, he contended that allowing states to impose taxes on national banks in this manner could potentially undermine these institutions' stability and effectiveness by subjecting them to varying local tax laws across different jurisdictions.