The U.S. Supreme Court case Smith et al., Partners, v. Davis et al., as Board of County Tax Assessors of Fulton County, et al., 1944 revolved around the issue of tax assessment and equal protection under the law. The plaintiffs were partners in a business who claimed that their property was assessed at a higher percentage of its value than other properties in Fulton County, Georgia - an alleged violation of their right to equal protection under the Fourteenth Amendment. They sought relief from paying taxes until this discrepancy was rectified by reassessing all properties at full cash value or assessing theirs proportionately lower to match others'. However, the court ruled against them stating that while there may be some inequality due to practical difficulties inherent in any tax system; it did not amount to intentional discrimination which would violate constitutional rights. Therefore, they found no grounds for interference with state taxation procedures unless clear and hostile discriminations against particular persons or classes are made out beyond rational dispute.

In the dissenting opinion for Smith et al., Partners, v. Davis et al., as Board of County Tax Assessors of Fulton County, Justice Robert H. Jackson disagreed with the majority's decision that a state could tax federal securities held by a bank in trust for its depositors. He argued that this was an indirect way to tax federal obligations and thus violated the constitutional principle of intergovernmental tax immunity. According to him, if states were allowed to impose such taxes on banks holding federal securities in trust, it would discourage banks from investing in these types of assets and potentially increase borrowing costs for the Federal Government. Furthermore, he pointed out inconsistencies between this case and previous decisions made by the Court regarding similar issues.