United States v. Seattle-First National Bank

Respondent initiated this suit to recover the amount of the documentary stamp tax, penalty and interest which had been exacted under the Revenue Act of 1926, as amended, in connection with a statutory consolidation of banks under § 3 of the National Banking Act. The District Court entered judgment for respondent for the amount of the tax and interest, 44 F. Supp. 603. The Circuit Court of Appeals held that the case was governed by one of its former decisions 3 and affirmed the judgment, 136 F. 2d 676. We granted certiorari, 320 U. S. 723, because this judgment was alleged to conflict with…