Virginia National Bank v. United States

CRAVEN, Circuit Judge:

Virginia law requires national banks to pay to the State a tax on shares of bank stock ($1 on each $100 share certificate) assessed against their stockholders. Title 58 Code of Virginia, ch. 10, § 58-465 et seq. Some stockholders (among whom are charities and insurance companies) are exempted from the tax. The banks are required by the State to pay directly to these exempt stockholders an amount equal to the tax that would be assessed against them were they not exempt. Title 58 Code of' Virginia, ch. 10, § 58-480.1. Virginia National Bank, taxpayer in the present case,…