Virginia National Bank v. United States

MEMORANDUM OPINION

MACKENZIE, District Judge.

Appropriately proceeding under the proper federal statute, the Commonwealth of Virginia has imposed a tax on the holders of the shares of stock of any bank doing business in Virginia.

Upon receipt of the list of stockholders and the number of shares held by each, the Commissioner of the Revenue assesses upon each such holder the tax provided in the statute and makes returns of this assessment to the State Department of Taxation and to the Bank. By statute, the Bank is then required to pay the tax thus assessed against the shareholders directly into…