Cite as: 524 U. S. 156 (1998)
Opinion of the Court
1987-1 Cum. Bull. 18; and (2) the Federal Government prohibits for-profit corporations from holding funds in NOW accounts if the interest is paid to the corporation, but permits corporate funds to be held in NOW accounts if the interest is paid to the TEAJF, see Federal Reserve's IOLTA Letter. In other words, the State does nothing to create value; the value is created by respondents' funds. The Federal Government, through the structuring of its banking and taxation regulations, imposes costs on this value if private citizens attempt to exercise control over it. Waiver of these costs if the property is remitted to the State hardly constitutes "government-created value."
In any event, we rejected a similar "government-created value" argument in Webb's. There, the State of Florida argued that since the clerk's authority to invest deposited funds was a statutorily created right, any interest income generated by the funds was not private property. 449 U. S., at 163. We rejected this argument, explaining that "the State's having mandated the accrual of interest does not mean the State or its designate is entitled to assume ownership of the interest." Id., at 162.
This would be a different case if the interest income generated by IOLTA accounts was transferred to the State as payment "for services rendered" by the State. Id., at 157. Our holding does not prohibit a State from imposing reasonable fees it incurs in generating and allocating interest income. See id., at 162; cf. United States v. Sperry Corp., 493 U. S. 52, 60 (1989) (upholding the imposition of a "reasonable 'user fee' " on those utilizing the Iran-United States Claims Tribunal). But here the State does not, indeed cannot, argue that its confiscation of respondents' interest income amounts to a fee for services performed. Unlike in Webb's, where the State safeguarded and invested the deposited funds, funds held in IOLTA accounts are managed entirely by banks and private attorneys.
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