National Bank v. United States was a case heard by the United States Supreme Court in 1879. The case centered around the question of whether the United States government had the authority to tax a national bank. The bank in question was the National Bank of San Francisco, which had been established by Congress in 1864. The bank argued that it was exempt from taxation under the terms of the National Bank Act of 1864. The government argued that the bank was subject to taxation under the terms of the Internal Revenue Act of 1864. The Supreme Court ultimately sided with the government, ruling that the bank was subject to taxation under the terms of the Internal Revenue Act. The Court reasoned that the National Bank Act did not explicitly exempt the bank from taxation, and that the Internal Revenue Act was a valid exercise of the government's power to tax. The Court also noted that the National Bank Act did not grant the bank any special privileges or immunities, and that the bank was subject to the same laws as any other business. The Court's decision in National Bank v. United States established the principle that the government has the authority to tax national banks, and that the National Bank Act does not grant any special privileges or immunities to national banks.

Justice Field delivered the dissenting opinion in National Bank v. United States, arguing that the federal government had no authority to tax state-chartered banks on their circulation of notes. He argued that Congress was not given any power to tax by the Constitution and thus could not impose a direct or indirect tax on such an institution as it would be unconstitutional. Furthermore, he argued that if Congress were allowed to do so, then they could also levy taxes on other private institutions which would be a violation of states' rights and individual liberties protected by the 10th Amendment. Justice Field concluded his dissent stating that allowing this taxation would give too much power to Congress over both individuals and states alike without proper constitutional authorization from either party involved.