In the 1939 case of Tradesmens National Bank of Oklahoma City v. Oklahoma Tax Commission, the U.S. Supreme Court ruled on a dispute involving state taxation and federal law. The bank argued that an Oklahoma tax statute was unconstitutional because it taxed national banks more heavily than other financial institutions within the state, violating their rights to equal protection under the Fourteenth Amendment. However, the court upheld Oklahoma's right to impose different taxes on different types of businesses as long as there is no discrimination against federally chartered entities in favor of those created by state law. The court found that while national banks were indeed taxed differently from some other corporations in certain respects, they also enjoyed unique privileges not available to others which justified this differential treatment.

In the dissenting opinion for the Tradesmens National Bank of Oklahoma City v. Oklahoma Tax Commission case, it was argued that the majority's decision contradicted previous rulings and principles established by the Supreme Court regarding tax exemptions. The dissenting justices believed that a state has no power to impose taxes on federal instrumentalities unless Congress explicitly allows it. They pointed out that in this case, there was no clear congressional consent allowing states to levy taxes on national banks' shares held by non-residents. Therefore, they disagreed with the majority's interpretation of Section 5219 of Revised Statutes as granting such permission implicitly or indirectly. Furthermore, they contended that even if Congress had granted such authority, any taxation should be uniform and not discriminate against non-resident shareholders.