$709,217,000 less than the estimate of the State assessors in 1860, $933,077,000 less than their estimate in 1864, and $660,712,000 less than what may be inferred from the incomplete returns of the census of 1865.

But the evidence mainly relied on in estimating the value of real property, is the rule of assessment adopted by the local officers, charged with the duty of administering the tax laws. That such a rule exists, is attested in the official correspondence of this office, and it has been frequently admitted in personal interviews with the financial officers of the State. There is, in fact, no reasonable doubt of the prevalence throughout the State, of a practice sanctioned by custom though contrary to law, under which, taking the average of towns and counties as equalized, agricultural lands are assessed at not more than one-third of their actual value, and the real estate of cities and villages at one-half. As the assessors in each county act independently, there are variations in the application of the rule more or less marked, rendering it necessary, in such cases, for boards of Supervisors to adjust the resulting inequalities between towns.

This, however, does not disprove the fact of an intention and design to assess property in something like the proportion stated, and it is believed that with few exceptions the rule is conformed to, with as much exactness as could be anticipated from the separate action of so many officers. Recent proceedings in one of the counties of this State may be cited in confirmation of this opinion. The supervisors of two of the towns, dissatisfied with the equalization of the board, appealed from its decision to the Comptroller, under the 13th section of the act, chapter 312, Laws of 1859. The evidence and proofs were taken before a referee appointed by that officer, and upon the testimony of a large number of witnesses, it appeared that the assessed value of the whole county was thirtyfive per cent of the true value as established by actual sales and otherwise. The lowest rate of assessment in any town was twentytwo per cent of the actual value, and the highest forty-five per cent, the rate in one of the towns that appealed, which included within its limits a large and populous village.

In taking the rule of valuation adopted in the assessments as the basis from which to estimate the value of real property, it is necessary to ascertain at the outset, what proportion of the aggregate equalized assessments returned to this office, say in 1866,

shall be assigned to cities and villages, and what proportion to towns. Cities are returned separately, but villages are generally included in the assessment of the townships in which they are situated, and in most cases therefore, the returns do not contain the data from which to make the distribution. The principle on which it is proposed to proceed for the purposes of this inquiry is, to divide all real estate into two classes, city and village property and agricultural lands, placing all townships where there are villages with a population of 3,000 or upwards in the first class, and all villages with less than that population in the second, and then ascertaining the true value of each, by adding one hundred per cent to the assessed value of the first, and two hundred to that of the second. Objection may be made to this method on the ground that the assessed value of villages with less than 3,000 inhabitants placed in the second class, is greater than the assessed value of the townships placed in the first. But there are no data on which the classification could be made with entire accuracy, and if the force of the objection be admitted, it would not destroy the value of the results arrived at as approximate estimates.

If then we take the aggregate valuations of real estate for the. year 1866, amounting to $1,236,288,147, and deduct from it the valuations of cities and townships, including within their limits villages of over 3,000 inhabitants, we find the assessed value of farms to be $473,779,106, and that of cities and villages to be $762,509,041, adding two hundred per cent to the first amount and one hundred to the second, we shall have $1,421,337,318, as the value of farms, $1,525,018,082 as the value of cities and villages, and $2,946,355,400, or in round numbers $3,000,000,000 as the total value of real property in the State at large.

Personal property may be divided into two classes: that held by corporations and that held by individuals. With respect to corporations, organized under the laws of this State, they are obliged to made annual reports of their affairs either to the Legislature or to some one of the State Departments; and it is also the duty of boards of supervisors to make annual returns to this office, of all corporations within their respective counties, with the amounts at which they are assessed. These reports and returns being made under the requirements of law, and usually verified by affidavits, their general correctness may be assumed. The reports which the National Banks of this State are required to make at stated periods to the Comptroller of the Currency, afford equally full

information. No account is taken of foreign corporations, as they are presumed to have no property here beyond the deposit required by our laws from foreign insurance companies, and the balances in the hands of their agents. With these explanations, it may be stated as the result of a careful examination of the reports and returns for 1866, which are the latest that could be obtained, that after deducting the assessed value of their real estate, which was included in the previous estimate given under that head, the personal property of corporations at the close of that year, including capital and surplus, exceeded the aggregate sum of $375,000,000.

Of the amount of personal property held by individuals, there are no data from which to form more than an approximate estimate. The term as defined in the statutes is a comprehensive one, including "household furniture, money, goods, chattels, debts due from solvent debtors on account, contract, note, bond or mortgage, public stocks, stocks in moneyed corporations, and such portion of the capital of moneyed corporations as is not invested in real estate."

To attempt to trace property studiously concealed by the possessors from the public view, through the hundred subdivisions of classification, much less to estimate the value with accuracy, would be a hopeless task. There is a moral certainty, however, that it amounts to an enormous sum. Take, for instance, the item of household furniture. Distributing the population of the State into families of five each, there would be 800,000 families. If one-half of them had no property whatever of this description, and the other half $500 to each family, it would make an aggregate of $200,000,000. Large as this sum may appear, there is scarcely a family in moderate circumstances that does not possess more than that amount, and as we ascend in the scale of wealth the proportion which the value of this kind of property bears to the domicile, increases, until we find the household goods, the paintings, the statuary, and other works of art, represented by sums little less than the value of the dwellings in which they are contained. Again, who would anticipate that the value of livestock and farming implements, would aggregate for the whole State $148,000,000, and yet we have the authority of the census of 1865 in estimating them at that sum. Then, again, the individual deposits in the State and National banks and savings institutions, according to the official statements of October 1st, 1866,

were $436,000,000, and in the distribution of the funded debt of the United States, the most cautious calculation could not reduce the amount held by individuals in this State below $250,000,000. An additional $250,000,000 may be added for investments in the debts of the several States, of cities and corporations and on bond and mortgage. The accumulations of our life insurance companies constitute another element of individual wealth, equal in amount to the value of the policies held by citizens of this State. Now, we can reason from subjects where we have some degree of light, to others that are more obscure. If a community of less than 4,000,000 of population can afford to invest $200,000,000 or more in unproductive property, merely for purposes of convenience and luxury, place $250,000,000 in the public funds, and perhaps as much more in other permanent forms of investment, what must be the extent of its active capital employed in the various branches of business, and represented by the products of the soil, the manufactory and the mine? We leave the answer to those who feel disposed to prosecute the inquiry, simply expressing the opinion, based on the estimate of an experienced underwriter, as to the amount covered by outstanding policies of insurance, that if the average value could be ascertained by a comparison of prosperous with unprosperous years, it would add to personal property, by an amount greater than any of the items previously estimated, and afford ground for the belief that, as defined in the statutes, its aggregate value in this State must nearly if not quite equal that of real estate.

It is doubtful, however, whether mere evidences of indebtedness should be included in a statement designed to show the value of personal property, because in reality they add nothing to the aggregate wealth. It is true they may greatly extend the scope of taxation, but as they are an encumbrance on land and productive industry, these interests are reduced in value by the amount for which they are pledged. If the public obligations of this State or of the United States were considered so much of an addition to property, it would lead to the absurd conclusion, that the wealth of a community was in proportion to the amount of its outstanding obligations, in face of the fact that those who hold them possess a claim on the future revenues of the Government, which is a direct charge on the results of capital and industry, and which impoverishes the nation in the same degree that it enriches the public creditors. In a more limited sense, the same observa

tion will apply to individual indebtedness, whatever may be its form, and if the power resided anywhere to enforce a general liquidation, its effect would be the cancellation of all property of this description, without directly reducing the real wealth of the country, however much it might tend indirectly to that result, by crippling its productive energies. For these reasons, and the additional consideration that the present tax laws allow the offset of debts, the estimate of personal property is correspondingly reduced, and there is probable evidence, at least, that it is not in excess of what would remain, on the supposition of a general liquidation and settlement.

On the facts and statements given in this connection, it is probable that the aggregate value of the property of the State in the present condition of the currency, cannot be less than $4,500,000,000 of which amount 3,000,000,000 is represented by real, and 1,500,000,000 by personal. It is conceded that the importance of a fact or inference, as a guide in forming an opinion, must be determined by the character of the evidence by which it is supported, and that where it is only presumptive, there is room for different conclusions. But with respect to real estate, there can be no concealment of it, and the proofs of its undervaluation are so plain and so commonly admitted, that the estimate can hardly be deemed excessive. Personal property, on the other hand, is so studiously withdrawn from the public view, and so difficult to trace through the numerous forms which it can assume, that when we pass from corporations compelled by law to disclose their affairs, and come down to the individual citizen, it is not possible to arrive at any thing like a satisfactory conclusion. There is ground to believe, however that under the system of listing which prevails in most of the States, the estimate would be found too low. How far it would be affected by a return to specie payment could not be determined. Such an event would undoubtedly reduce the price of the products of industry, and perhaps of land, though in a much less degree.

The next step in the inquiry is to consider briefly the relation between property and its rents and profits, or, in other words, the annual results of capital and labor.

From an official statement of the Commissioner of Internal Revenue, for the fiscal year ending June, 1867, it appears that the total income tax paid by this State was $17,794,352.64, of which $7,620,608.39 was at five per cent, and $10,173,744.25 at