Memphis City Bank v. Tennessee Ex Rel. Memphis

Citations

• 161 U.S. 186
• 16 S. Ct. 468
• 40 L. Ed. 664
• 1896 U.S. LEXIS 2151

Syllabus

<p>A corporation organized for the purpose of doing an insurance business, under an act of the legislature of the State of Tennessee passed befóte the adoption by that State of its constitution of 1870, with a provision in the charter limiting the rate and extent of taxation by the State, does not continue to enjoy the exemption if its corporate objects and business are changed to those of a bank by legislation enacted subsequent to the adoption of that constitution.</p> <p>A judgment in favor of the exemption of its shareholders from taxation in excess of the statutory limit, entered before the insurance company was. changed to a bank, cannot be upheld as res judicata in an action brought after the change to recover such excess.</p>