to the general property tax will enable the Board of State Tax Commissioners to greatly reduce the field force at present employed. With cash value assessments established in every county, there will no longer be need of five or six months special work by a large force, to enable the Commission to properly report the cash value of each county to the State Board of Equalization. The counties would simply be reported at their value as established by the re-assessment, supplemented by proper reports bringing them down to date. There would be few appeals from county equalization and such as might be made would be decided without special preparation because of the cash value of the townships being on file with the State Tax Commission. There would be few appeals from the supervisors' assessments, and those could be settled directly in correspondence with the supervisor and aggrieved taxpayer. The saving in salaries because of the reduction in the field force would be accompanied by an almost equal saving in expenses incurred by field men when at work. It cannot be promised that all field work would cease. There would still be need of expert examiners, especially for the first two years, to smooth down the high places and fill in the low ones, and it would still be necessary to annually check up the work of supervisors, especially in the rapidly developing sections of the State; but it is safe. to say that following the assessment year of 1917 fully seventy-five per cent of the field force of the Commission could be dispensed with, and with a corresponding saving in both salaries and expenses. If after the establishment of cash value throughout the State, the districts found assessed below cash value were required to pay the expenses of a re-assessment as is elsewhere recommended in the report, the support of the State Tax Commission would no longer be a burden.

RECOMMENDATIONS AS TO LEGISLATION.

The operation of the ad valorem general property tax system in Michigan has, for the most part, been satisfactory. It is the only system of taxation with which the taxpayers of the state are familiar. Its basic principles are so entrenched in the constitution of the state that any material change in them is impossible without changing that instrument itself, as well as a large part of the general tax law. For this reason, such subjects as separation of state and local taxation, transfer of the taxes paid by public service corporations from the primary school fund to the general fund of the state, substitution of a graduated income tax for intangible personal property taxes, the classification of property and the application of different rates of taxation to different classes, because they would involve first amending the constitution, are hardly to be considered by the Tax Commission in its recommendations to the legislature; but recommendations of changes in, or additions to existing laws, that will, in the judgment of the Tax Commission, tend to bring about greater equality of burden, promote "cash value" assessments, or better administration of the present system, do properly come within the duties of the Board of State Tax Commissioners. The report of the State Tax Commission for the two years ending December 31st, 1914, considered the question of changes in the existing system at length, but no action was taken on any of the recommendations by the legislature. Further experience has so strengthened our opinion as to the desirability of many of the changes then recommended, that we feel justified in repeating them in this report.

REQUIRE STATEMENTS FROM CORPORATIONS.

"Require all industrial and mercantile corporations doing business in the state to make to the Board of State Tax Commissioners, not later than the second Monday in April of each year, full and complete sworn statements in writing upon forms furnished by said state board, giving in detail such information as said board may deem necessary for properly determining the true valuation of the property of such corporation, similar statements to be required of any firm or association when deemed necessary to properly value the business or property of such firm or association; copies of such statements to be furnished to the local assessing officers as soon as practical after the second Monday in April."

The proper assessment of industrial and mercantile corporations, next to assessment of intangible property, has always been the most difficult problem in our assessment system. To assess this class of property correctly and uniformly throughout the State, requires a high degree of technical knowledge and business experience, as well as complete information as to the financial affairs of the corporation to be valued. Local assessors rarely have the particular qualifications for such work,

or, possessing the qualifications, are able to secure a complete disclosure of its affairs by a corporation. There is, also, extant in many communities a public sentiment favorable to the encouragement of industrial enterprises through low taxation, so strong that assessing officers are influenced by it. The statutory definition of "cash value" as being the usual selling price of property at assessment times, cannot always be followed by assessing officers, as such properties are rarely bought and sold. Some other method must be employed with the inevitable result, that great diversity of method, and much unintentional departure from "cash value" will follow.

The Board of State Tax Commissioners in its reviews of assessments, and in its plan of co-operation with supervisors, has examined and valued many hundred industrial and mercantile corporations. It has almost universally found the officials of such corporations willing to make disclosures to its representives, and to co-operate with them for the proper assessment of such corporations. On the completion of the review of assessments throughout the state, and the assessment of all property at its true cash value, it is very desirable not only that local assessors be in a situation to properly review such assessments on a basis uniform throughout the state, but, also, that the Board of State Tax Commissioners be able to check up such assessments without the expense and delay of personal visits to such corporations. The assessing officer is now required to report his assessment of corporations to the Board of State Tax Commissioners, but in the absence of information by which to check such assessments, his reports are of little value.

It is the belief of the Board of State Tax Commissioners that the system of reports and statements above suggested, would enable the local assessing officer and the local board of review, to make and review such assessments correctly and uniformly at "cash value,” and also give the Board of State Tax Commissioners information for suggesting to an assessing officer the proper assessment when called upon so to do. It would also enable the Tax Commission to review the assessing officer's valuations without visiting the property, in case examination and comparison of the report of a corporation and the supervisor's assessment indicated that the assessment had not been properly made.

It might be urged that such corporations are now required to make annual reports to the Secretary of State, and that the Tax Commission has followed the practice of furnishing such reports to assessing officers. Experience has shown the reports made to the Secretary of State to be of little value to an assessing officer and often very confusing. The reports here recommended would contain the particular information assessing officers require, and would place the assessment of such property on a uniform basis throughout the state.

ASSESSMENT OF PUBLIC UTILITY CORPORATIONS NOT PAYING TAXES INTO THE PRIMARY SCHOOL FUND OF THE STATE.

"Provide for the assessment by the State Board of Assessors of interurban railroads, light and power companies, and all corporations whose property extends through more than one assessing district and not now assessed by the Board and for the equitable apportionment of such assessment among the several assessing districts in which located."

The State Board of Assessors now makes the assessment of all public service corporations whose taxes go into the primary school fund, and for the very obvious reason that such properties, regardless of the efficiency of the assessing officer in whose district they are located, can only be properly valued and taxed as a corporate unit. Local assessing officers, even when qualified, can only pass upon the physical property located in their districts, and aside from its relations to other parts which go to make up the corporate unit. They cannot determine intangible values, nor to what extent their assessing district should participate in values, tangible and intangible, which are not under their immediate jurisdiction. These same conditions apply to many public service corporations not paying taxes into the primary school fund, such as interurban roads, light and power lines, and to many industrial corporations. All of these, to be properly valued, must be valued as a corporate unit, and by an examiner possessing the necessary qualifications for the work and having access to detailed reports of the financial operations of the corporation. In its work reviewing assessments, the Board of State Tax Commissioners has found such corporations extending through as many as twenty assessing districts, and valued by as many different assessing officers, with no expert appraisals of property, no reports of business operations, and with valuations on the same class of property differing in almost every district. The system now in use by the State Board of Assessors for assessing railroads and corporations paying taxes into the primary school fund of the state, could easily be extended to include these aforesaid corporations.

We must not be understood as suggesting that these corporations should be assessed and taxed for the benefit of the primary school fund of the state, but simply that the Board of State Tax Commissioners should assess such property as a unit, and then apportion such assessment among the several assessing districts in which located, and certify the value thus determined for each district to the local assessing officer to be placed upon his roll. There is a tendency on the part of some corporations, especially interurban roads, to re-incorporate under the general railroad law, by which action their property disappears from the local rolls and is taxable only for the benefit of the primary school fund. We regret this tendency, and believe that should the suggested method of assessing such property be put into operation, it would have some influence toward preventing such re-incorporation.

REVISION OF ALL LAWS EXEMPTING PROPERTY FROM TAXATION.

"Revise, consolidate and make uniform the various laws granting exemption from taxation, in whole or in part."

"Repeal the law exempting from taxation credits that can be offset by debits."

The granting of exemptions from taxation has been practiced for so many years, and accomplished under so many legislative acts, and extended to so many individuals, associations and organizations, that much confusion exists as to what property is intended to be exempted, and much diversity in the practice of supervisors throughout the state. The amount and value of property exempted from taxation in some communities, is so considerable as to seriously affect the tax rate, and

raises a question as to the propriety and justice of many exemptions made by local officials, and as to the legality of some that are given. On no point are assessing officers more at sea, in nothing is their practice more dissimilar, on no point is information oftener asked of the Tax Commission. We believe that justice to the great mass of taxpayers calls for thorough revision of the laws governing exemptions from taxation. In connection with the suggested repeal of the law authorizing the exemptions from taxation of credits that can be offset by debits, we call attention to the fact that no part of the assessment of the real estate of a taxpayer can be offset by indebtedness of the owner, even when such indebtedness is a lien upon the property; nor any part of the assessment of personal property, such as live stock of a farmer, or goods of a merchant, because the farmer or the merchant is in debt, even when the debt was contracted to purchase the cattle or the merchandise. Why, then should an intangible credit, subject to taxation, be exempt because offset by an intangible indebtedness, especially when the indebtedness may have been contracted for some purpose in no way connected with the credit which it exempts from taxation. The fundamental principle of the general tax is "equality of burden" for all classes of property, and this would be greatly promoted by the repeal of the law authorizing exemptions of credits. Such repeal would add to the assessment roll millions of dollars of property now legally exempt, and millions more, illegally exempt, because of using this law as a subterfuge. There are hundreds of taxpayers in the larger assessing districts now contributing nothing toward the maintenance of government, who would be made taxpayers by the repeal of this law.

REQUIRE TRUE CONSIDERATION TO BE GIVEN IN DEEDS.

"Amend the law relative to the recording of deeds of conveyance of real estate so as to prohibit the recording of same unless the true consideration is given in the deed and an affidavit of the grantee attached to such deed, setting forth that the consideration in such deed is true and actual."

The constitution requires property to be assessed at its true cash value. The legislature has declared that the term "cash value" shall be held to mean the usual selling price of property and the courts have declared: "it is a cardinal rule that must never be forgotten that whatever property is worth for the purposes of sale, it is worth for the purposes of taxation.”

Whatever will assist assessing officers in determining the true "cash value" of property and enable them to make a more just and equitable assessment is beneficial to the entire state. The community's judgment as to the value of real estate is certainly one of the best and safest guides to follow and departure from a true statement as to the actual consideration at which title of real estate passes rarely has but one purpose, and that to mislead as to the true value of the property. So common is this practice in some communities that it is absolutely unsafe for the assessing officer to make any use of the consideration named in real estate transfers. In other communities the consideration named is often in excess of the true consideration, for the purpose of deceiving those seeking to purchase property. If the true consideration for all real estate