United States Trust Company of New York, Appellant v. the Mayor, Aldermen and Commonalty of the City of New York…

Summary

The New York Court of Appeals affirmed the lower court's decision that the tax assessments against United States Trust Company were not subject to a collateral attack because the tax commissioners had jurisdiction over the corporation and the subject matter. The court held that the exclusive remedy for erroneous assessments is a writ of certiorari, and therefore the plaintiff's action to recover the taxes paid was not maintainable.