AMERICAN BANK & TRUST CO. v. DALLAS COUNTY

No. 81-1717.

463 U.S. 855 (1983)

AMERICAN BANK & TRUST CO. ET AL. v. DALLAS COUNTY ET AL.

Supreme Court of United States.

Decided July 5, 1983


Attorney(s) appearing for the Case

Marvin S. Sloman argued the cause for petitioners. With him on the briefs were Brian M. Lidji, Peter S. Chantilis, Cecilia H. Morgan, Roy Coffee, Christopher G. Sharp, and Bruce W. Bowman, Jr.

Ernest J. Brown argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Lee, Assistant Attorney General Archer, and Michael L. Paup.

Carroll R. Graham argued the cause for respondents City of Dallas et al. With him on the brief were Douglas H. Conner III and Jan W. Fletcher. Earl Luna argued the cause for respondents Dallas County et al. With him on the briefs was Randel B. Gibbs. Henry D. Atkin, Jr., filed a brief for respondents Richardson Independent School District et al. Charles M. Hinton, Jr., filed a brief for respondents City of Garland et al.

Briefs of amici curiae urging affirmance were filed by Michael J. Bowers, Attorney General, Robert S. Stubbs II, Executive Assistant Attorney General, H. Perry Michael, First Assistant Attorney General, Verley J. Spivey, Senior Assistant Attorney General, and James C. Pratt, Assistant Attorney General, for the State of Georgia; and by C. Richard Fine for the Texas Association of Appraisal Districts et al.

Briefs of amici curiae were filed by Mike Westergren, Alan Gallagher, J. Bruce Aycock, and Felix Hallum George, Jr., for Nueces County, Texas, et al.; and by Jay D. Howell, Jr., and Daniel Doherty for the City of Houston.


JUSTICE BLACKMUN delivered the opinion of the Court.

The question presented is whether a Texas property tax on bank shares, computed on the basis of the bank's net assets without any deduction for tax-exempt United States obligations held by the bank, violates Rev. Stat. § 3701, as amended. The Texas Court of Civil Appeals ruled that it did not.

I

Until 1959, Rev. Stat. § 3701, 31 U. S. C. §...

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