In the 1923 case First National Bank of Greeley v. Board of County Commissioners of the County of Weld, the Supreme Court ruled on a dispute over taxation between a national bank and local government authorities. The First National Bank argued that it was exempt from certain taxes imposed by Colorado's Weld County because its shares were already taxed under federal law, thus making additional state or local taxation unconstitutional due to double jeopardy laws. However, the court disagreed with this argument and upheld Weld County's right to tax these shares as property owned by individual shareholders rather than assets belonging directly to the bank itself. This decision clarified that while national banks are federally regulated entities, they can still be subject to state and local taxes in some circumstances.

In the dissenting opinion for First National Bank of Greeley v. Board of County Commissioners of Weld County, it was argued that the majority's decision to uphold a tax assessment on bank shares failed to consider important factors. The dissenting justices believed that in assessing taxes on bank shares, one must take into account not only their face value but also any liabilities attached to them such as debts or mortgages. They contended that ignoring these liabilities resulted in an unfair and inflated valuation of the property being taxed. Furthermore, they disagreed with the majority's interpretation of Colorado law regarding taxation and felt it was inconsistent with previous rulings by both state courts and this Court itself. In conclusion, they asserted that this ruling would lead to unjust taxation practices against banks which could potentially harm their operations and overall financial stability.