In 1819, Ohio passed a law that put a tax on the Bank of the United States on the theory that taxing the bank would allow the state government to receive and distribute the scarce money.

On September 17, 1819, Ohio Auditor Ralph Osborn was given permission to seize $100,000 from a branch of the Bank of the United States.

Osborn argued that he had never been properly served with the order but still had to return the money.

In 1824, the Supreme Court ruled in favor of the Bank of the United States and ordered the return of the disputed $2,000.

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