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In Louisville v. Savings Bank, the Supreme Court was asked to decide whether a state-chartered savings bank was subject to a state tax on its capital stock. The bank argued that it was exempt from the tax because it was a federally chartered institution. The Supreme Court held that the bank was not exempt from the tax because it was a state-chartered institution. The Court reasoned that the bank was subject to the state's taxing power because it was created by the state and was subject to the state's laws. The Court also noted that the bank was not a federal institution and was not subject to federal laws. The Court concluded that the bank was subject to the state's taxing power and was not exempt from the tax. The decision established that state-chartered institutions are subject to the state's taxing power, even if they are federally chartered.
Justice Field, in his dissenting opinion for the case of Louisville v. Savings Bank, argued that the Court should have affirmed the decision of the Kentucky Supreme Court which held that a bank could not be taxed on its capital stock or surplus profits. He reasoned that this was because such taxation would amount to double taxation and thus violate both state and federal laws. Furthermore, he noted that if banks were allowed to be taxed on their capital stock or surplus profits then it would create an unequal burden among different classes of citizens since only certain types of businesses are subject to such taxes while others are exempt from them. Finally, Justice Field concluded by stating that allowing states to tax banks' capital stock or surplus profits would also lead to increased costs for consumers as these additional taxes will likely be passed onto them through higher prices charged by banks for services rendered.