The United States Supreme Court case, United States v. National Bank of Commerce (1984), revolved around the issue of whether a bank could refuse to comply with an IRS levy intended to collect unpaid taxes from a delinquent taxpayer's joint account. The National Bank of Commerce argued that it was unable to determine what portion of the funds in the joint accounts belonged solely to the delinquent taxpayer and thus, they couldn't honor the levy without potentially infringing on other account holders' rights. However, in its decision, the Supreme Court ruled against this argument stating that under federal law (26 U.S.C Section 6332), any person who fails or refuses to surrender property or rights upon demand by IRS is liable for such tax. Therefore, banks are required to honor an IRS levy on a joint bank account even if it cannot determine which portion belongs specifically to the delinquent taxpayer.

In the dissenting opinion for United States v. National Bank of Commerce, Justice Thurgood Marshall argued that the majority's decision was a misinterpretation of federal tax law. He contended that allowing banks to withhold funds from customers' accounts in order to pay their overdue taxes violated both the spirit and letter of existing legislation. According to him, this ruling would unfairly burden taxpayers who were already struggling financially by depriving them access to their own money without due process or proper notification. Furthermore, he expressed concern about potential abuse by government agencies and financial institutions if they were given such broad powers over individuals' private property rights without adequate checks and balances in place.