BANKS AND BANKING - TAXATION OF NATIONAL BANK - SAFE DEPOSIT VAULT AS INTEGRAL FUNCTION OF NATIONAL BANK

The council of the city of Portland passed an ordinance declaring it unlawful to carry on certain businesses without securing an appropriate license from the city. Among the business activities specified was "Safe Deposit Vault" for which an annual license fee of forty dollars was imposed. The plaintiff, a national bank, and other national banks, all of which operated safe deposit vaults, brought an action to restrain the city and its officers from collecting the fee. It was held that the safe deposit business is a necessary and integral function of a national bank, and therefore the city was without power to collect such a tax.

Bank of California v. City of Portland, (Ore. 1937) 69 P. (2d) 273.