In Federal Land Bank of New Orleans v. Crosland, (261 U.S. 374, 43 S Ct 385, 67 L Ed 703 [1923]), the United States Supreme Court had the opportunity to consider other states' mortgage recording taxes, similar to New York State's MRT. The Court held that an Alabama law imposing the collection of a tax upon the registration of a mortgage was a tax on the mortgage itself. As a consequence, the Court held that it could not be collected from the Federal Land Bank, an instrumentality of the United States which was otherwise exempt from state taxation.