But that this state of affairs is not peculiar to New York, is made evident by the following extract of a letter written to the commissioners by an official of a neighbouring State :

"The practice on the part of assessors in nearly every town in the State, has been to make oath that the real estate has been appraised by them at such sums as they would appraise the same in payment of a just debt due from a solvent debtor ;' while current sales showed that land was seldom actually appraised above one-third of its value. This being the case with real estate, which was appraised only once in five years, the practice was in many towns to do the same by personal property, and only put on one-third of that, while other towns put it on at least one half, and others at full value. Then again work effectually. He placed in one column the actual cost value of the real estate of every town in that county, and the value at which, as estimated, it was sold from day to day. In the other column he placed the assessed value of the property of each town in that county. The lowest rate of assessment was at twenty-two and one-half per cent; the highest was fortyfive per cent; the average was thirty-three and one-third per cent. The assessment was not correct, and the town was relieved. It was shown that the board of equalisation, in making up its account, had taxed the town at forty-five per cent, whereas they had put part of the county as low as twenty-two per cent. There is a county in this State, in the vicinity of the county in which I live, which, in point of population, in geographical area, is larger than the county from which I am, which has added within the last ten days to its return of assessments about eleven millions of dollars by the board of equalisers; and yet it now stands almost one-third less in valuation than my county. Everyone who knows the situation of those two counties knows that the one which is larger in point of population and larger in area has vastly more wealth than my county."-T. G. Alvord, Ibid., vol. iii., p. 2321. "I know the fact that real estate is assessed unequally. In some localities it will not exceed one-fifth of its value, and in others onethird; others, one-half to two-thirds."-A. F. Allen, Delegate 32nd District, vol. iii., p. 1901. I had supposed the present law required that all property be assessed its actual value; but the practice is much worse than the principle. The practice, so far as I understand it, is to assess real estate at about one-third of its value, and to assess personal property, so far as it can be discovered, at nearly its full value; so that really the honest man is oppressed, while the ingenious rogue goes scot free."-Jas. A. Bell, Delegate from the 18th District, Chairman of Joint Committee of Legislature, 1862-23, on Revision of Tax Laws; Debates Constitutional Convention, vol. iii., p. 1909. "I believe that it is difficult to conceive of a system of distributing the burdens of a civilised community so that it would operate more gross injustice than the actual system of taxation as it now exists among us. This system is not only grossly unjust, but it is demoralising to the last degree. Your assessor takes up the assessment-books with the perfect consciousness that, do what he will, his neighbour who owns land is to be robbed. His neighbour knows that, and the consequence is that the assessment of real estate never tells the truth. Real estate is never assessed truthfully, and thus a general demoralisation ensues. I insist that a people cannot prosper whose officers either work or tell lies. There is not an assessment-roll now made out in the State that does not both tell and work lies."-M. I. Townsend, Delegate at Large, Troy, N. Y., Ibid., vol. iii., p. 1945. "It is undoubtedly true that not one-half-I think I may say onequarter-of the property, real and personal, in this State, is reached by the assessor."-David Rumsey, Delegate of 27th Senatorial District, Ibid., vol. ii., p. 1947.

the valuation in real estate caused individuals to 'take care of themselves' by secreting or holding back from the listing the larger share of their personal estate. Our laws, too, allow offset against personal property (not against real estate), and practically we found people heavily in debt at the time the assessors made their appearance-all this evasion and fraud to avoid paying too much State and county taxation. I was one of the assessors in this year, and assisted in appraising the real estate, and the footings were over five and a half times as large as they were five years ago. The appraisal was equalised with fifteen towns in this county by another county board, and they reduced the appraisal to less than two millions. Then a State board averaged the counties of the State, and raised this county fifty per cent; and that leaves our real estate standing out between fifty-one and fifty-two per cent of its selling value. Careful examination of appraisals and of records of transfers show that some towns making the same oath we made had only put their lands in at thirty-one and one-fourth of its current selling value. Even under this outrageous practice our Legislature, which has just adjourned, could not be induced to pass any listing law.”

VALUATION OF PERSONAL PROPERTY.

But great as may be the inequalities in the valuation and assessment of real property, those which obtain in respect to personal are so much greater, as to almost preclude the idea of comparison.

A careful consideration and study of the nature and classification of property inclines the commissioners to indorse the correctness of an opinion which appears to have been originally proposed by a financial writer of New York,* as far back as

*"The statistics presented by assessments of property for the purposes of taxation invariably exhibit the estimated value of land, and its meliorations under the head of 'real estate,' and the estimated value of all other productive capital under the head of 'personal estate.' Assessments made with the view of obtaining information for the guidance of statesmen, or for historic data, usually observe the same rule of classification. Thus divided, we may readily infer that the value of real estate greatly exceeds that of personal estate, and so these statistics invariably indicate. But if we take the estimate for any given village, town, or city, and from the gross value of the real estate deduct the value of the buildings, and add it to the personal estate, we shall then find them equal, provided its assessment has been correctly made, which, by the way, very rarely occurs.

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Now, as to observation, those who are familiar with the value of property in the city of New York (any other city would serve equally well as an illustration) are aware that the market value of the land on which it is built is much greater than the value of the buildings; that if each building lot and each building in the city should be separately put up at public sale, and sold to the highest bidders, the aggregate price of the lots would greatly exceed that of its buildings. But if the productive capital contained in th

:

1851, viz. "That, universally, the market value of the aggregate of land and that of the aggregate of productive capital are equal;" and, further, that in highly civilised and densely populated States, like New York, Massachusetts, Rhode Island, &c., the separate aggregates of property generally classed under the two heads of "real" and "personal," either equal, or closely approximate to each other in actual value. In the light of this theory, let us next inquire how far any degree of conformity of valuation for taxation of these two classes of property can be found in the results of recent practice and experience. The following table shows the separate aggregate valuations of real and personal property for assessment and taxation in the States of New York, Massachusetts, Ohio, Iowa, and Illinois, for the years 1869-'70 (under a corresponding system of assessment and valuation), together with the ratio of the respective valuations in question:

a Including $16,280,960 assessed under the head of railroad property.

buildings should be included with them, then the gross price of the two would be about equal. This is in accordance with our theory, and we think that observation strongly supports the position, if it does not establish its soundness. A striking evidence of its truth is afforded in the well-known fact that each lot will bring a price corresponding with the amount of productive capital either upon it or in its immediate vicinity. Take Wallstreet, for example, where the buildings are most costly and contain most of productive capital; there the value of land is greatest. Take a portion of the city above, the buildings are poor, and the locality remote from the productive capital employed in commerce; there the value of the land is least. Here it should be remarked that buildings and parts of buildings designed for ornament rather than for use do not come under the denomination of productive capital. The true test of productive value belonging to a house, store, or other building is the rent it will command, independent of the ground-rent. It is to be observed, also, that productive capital influences the market value of land beyond the immediate spot on which it is placed. For this reason it would be necessary, in order to render the two exactly equal in New York, or any other city, to include the suburbs and adjoining lands in the estimate. Again, little more than half a century has elapsed since the land on which the city of Cincinnati stands was purchased at one dollar per acre. There was then no capital there: now there are many millions of capital there; and hence we now find the market value of the land, exclusive of the erections, as many millions. It is thus of all other cities, towns, and villages throughout the civilised world; and it it thus in all agricultural districts; but in these the land and its meliorations are so much more intimately blended that we cannot perceive the facts so readily. The

D

The following table also exhibits the separate aggregate valuations of real and personal property in several of the cities of New York and of other States, for the year 1869-'70 (under a corresponding system of assessment and valuation), together with the ratio of the respective valuations in question :

a Although the official figures indicate an approximative equality in the valuation of real and personal property in the city of Providence, it is nevertheless probable that the inequality is really very considerable; possibly as great as in any city of the country.

Attention should be called to the circumstance that cases are not unfrequent in which the valuation of the personal property of certain towns and cities for taxation is in excess of the valuation of the real property. Thus, for example, in the city of Cincinnati, in 1866, the valuation of the real estate was $66,454,662, and of personal property $67,218,101; but it is eurious to note, that three years subsequently, or in 1869. when the tax rate had advanced from 2.16 to 3.19, the valuation of personal property shrunk from $67,218,101 to $58,471,166, or over twelve per cent. Again, in Massachusetts, which is the only State which publishes in full detail its valuations and assessments, the valuations for 1869-'70 exhibit the following cities and towns as possessing an aggregate of personal in excess of real property, viz.: Salem, Nahant, Nantucket, Brookline, Brewster, Dennis, Provincetown, Wellfleet,

truth is, the market value of land is merely the reflection of the value of the productive capital placed upon it and its immediate vicinity. It has no real value of its own; it costs nothing to produce; but since the laws have endowed it with the vital principle of wealth by subjecting it to individual ownership, it can no longer be obtained without giving in exchange for it an equivalent portion of the capital present and designed to concur with it in the production of wealth."-Treatise on Political Economy, George Opdyke, page 89-91; New York, 1851, G. P. Putnam & Co.

Yarmouth, Great Barrington, Stockbridge, New Bedford (in the proportion of 14 to 8), Hatfield, Milton, and others; while in many others the approximation in valuation of the two classes of property is very close.

The following table shows the comparative valuation and ratios of the real and personal property in several of the counties of New York, as shown by the Comptroller's report for 1870:

In Oneida county the assessed value of personal property in 1842 was $2,217,975; and in 1869, $2,166,411, showing a decrease in twenty-seven years of $51,564. But the national bank capital of two cities of this county, on the 1st of October, 1870, with surplus and undivided profits, was $2,172,000, or $6,411 more than the whole personal property of the county returned during the same year for assessment.

In 1835 the personal estate of Westchester county was returned at $2,324,693, with a population of 38,789. In 1870, with a population considerably in excess of 100,000, the assessed value was $7,709,512; or only $4,928,880 in excess of what it was in 1853.

In 1858 the personal estate of Dutchess county was assessed at $7,701,502; in 1870, at $8,825,233; showing an increase in twelve years of only $1,123,731.

In 1868 the personal estate of Erie county was assessed at $11,431,680; in 1870, at $8,155,240; showing a decrease in two years of $3,276,440.

In Monroe county personal estate was assessed in 1858 at $4,414,362; in 1870, at $2,739,692; showing a decrease in twelve years of $1,674,670. In 1865 the value of the farm stock of this county was returned at $3,408,109; and of farm implements at $941,997. The capital surplus, and undivided