In the 1984 case of First National Bank of Atlanta v. Bartow County Board of Tax Assessors, the U.S. Supreme Court addressed a dispute over property tax assessments in Georgia. The bank had acquired several properties through foreclosure and claimed that these should be assessed for tax purposes at their fair market value on January 1st, as per state law. However, the county board argued that since the bank took possession after this date but within the same year, they were entitled to reassess them at a higher rate based on their current market value when taken into possession by the bank. The court ruled in favor of First National Bank stating that under Georgia law, all real estate must be assessed for taxation as it stands on January 1st each year and no changes can occur until next assessment period even if ownership changes during said time frame.

In the dissenting opinion for First National Bank of Atlanta v. Bartow County Board of Tax Assessors, Justice White disagreed with the majority's interpretation that federal law prohibits state taxation of a national bank's intangible property. He argued that Congress did not intend to exempt all forms of intangibles from state taxation when it enacted 12 U.S.C § 548 and its predecessor statutes. Instead, he believed these laws were designed to prevent states from discriminating against national banks by taxing them more heavily than their local counterparts. The justice also pointed out inconsistencies in previous court rulings on this issue and suggested that they should be overruled if they are found to conflict with Congressional intent or lead to unjust results. Furthermore, he expressed concern about potential negative impacts on states' revenue sources due to broad interpretations of tax exemptions for national banks.