In County of Yakima v. Confederated Tribes and Bands of Yakima Nation, 502 U.S. 251 (1992), the United States Supreme Court held that Yakima County had authority to impose an ad valorem tax on reservation land patented in fee pursuant to the Indian General Allotment Act of 1887. Id. at 270. This Act empowered the President to allot tribal lands without the consent of Indian nations, and further provided that the United States would hold the land in trust for the allottee for a period of 25 years. Id. at 254. After the trust period had expired, a fee patent would be issued. Id. The Burke Act of 1906 altered portions of the General Allotment Act to provide for state civil and criminal jurisdiction at the expiration of the trust period, when the lands were conveyed to the Indians by fee-patent. Id. at 255. The Burke Act proviso also specified that "all restrictions as to the sale, incumbrance or taxation of said land shall be removed." Id. The Supreme Court noted that "by specifically mentioning immunity from land taxation 'as one of the restrictions that would be removed upon conveyance in fee,' Congress in the Burke Act proviso 'manifested a clear intention to permit the state to tax' such Indian lands." Id. at 259.