<P> Chief Justice Marshall also determined that Maryland may not tax the bank without violating the Constitution . The Court voided the tax on the grounds that it was unconstitutional . The opinion stated that Congress has implied powers that need to be related to the text of the Constitution, but need not be enumerated within the text . This case was a seminal moment in the formation of a balance between federalism, federal power, and states' powers . Chief Justice Marshall also explained in this case that the Necessary and Proper Clause does not require that all federal laws be necessary and proper and that federal laws that are enacted directly pursuant to one of the express, enumerated powers granted by the Constitution need not comply with the Necessary and Proper Clause, holding that the clause "purport (s) to enlarge, not to diminish the powers vested in the government . It purports to be an additional power, not a restriction on those already granted ." </P> <P> Though Marshall rejected the 10th amendment's provision of states rights arguing that it did not include the word "expressly" unlike the Articles of Confederation, which was replaced by the Constitution, controversy over the authority of the amendment being violated by the decision has existed . Compact theory also argues that the federal government is a creation of the states where the states maintain superiority . Unlike Marshall, his successor, Roger B. Taney, established Dual federalism, where separate but equal branches of government were believed to be a better option . </P> <P> McCulloch v. Maryland was cited in the first substantial constitutional case presented before the High Court of Australia in D'Emden v Pedder (1904), which dealt with similar issues in the Australian Federation . While recognizing American law as not binding on them, the Australian Court nevertheless determined that the McCulloch decision provided the best guideline for the relationship between the Commonwealth federal government, and the Australian States, owing in large part to strong similarities between the American and Australian constitutions . </P>

How did mcculloch v. maryland strengthen the federal government