The first battle of implied powers of Congress was fought over the formation of banks. In 1790, Alexander Hamilton urged Congress to set up a national bank. Opponents of this claimed that Constitution didn't give Congress that power to establish such a bank. Hamilton won after reviewing the Necessary and Proper Clause. this battle and the first national bank was established in 1791. However, it's charter expired in 1811. During the 20 years it was opened, it was unchallenged by the courts.
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