UNITED STATES ET AL. v. COUNTY OF ALLEGHENY, 322 U.S. 174

Summary

Petitioner United States entered into a contract with petitioner corporation to manufacture weapons, whereby the United States would furnish at its cost certain necessary equipment that would remain the property of the United States. Pa. Stat. Ann. tit. 72, § 5020-201 imposed an ad valorem tax on real property located in the state. The county assessor added the value of the machinery to the value of the real property to determine the amount of tax owed by the corporation. The Supreme Court reversed a decision upholding the validity of the tax, holding that under the Supremacy Clause, U.S. Const. art. I, cl. 2, federal law governed the construction of contracts by which the U.S. exercised its constitutional functions, and the contract provided that title to the machinery remained in the United States, and the assessment included the value of the machinery, so that portion of the property was immune from taxation, regardless of whether the tax was imposed on the government itself or upon...