less than its failure to produce substantial results, that led the state legislature, at its first session thereafter, in 1900, to repeal the biennial revision and listing features and to substitute in lieu thereof, continuing revision and quinquennial reassessment.

There is no reason to suppose that the relisting of securities in 1898 was any more efficiently administered than the revision of general personalty. Indeed, from the greater delicacy of the task and the greater difficulty of its supervision, there is much reason for suspecting that the results were relatively even less favorable.

Unsatisfactory as they may have been, however, the results of the 1898 revision formed the basis of securities taxation for the next three years, with only such additions as accrued through the proneness of the Appeal Tax Court to pounce down upon unfortunate or unwary holders, heretofore untaxed. In 1901, however, under a new municipal administration the Appeal Tax Court made some deliberate effort to secure a larger return of securities for tax purposes. Starting at Centre Street, a wedge-shaped district extending east of Madison Avenue and west of the Falls, and widening north to North Avenue as far as Walbrook, and as far east as the York Road, was, in the course of 1901-03 "rescheduled"; that is, every house-owner in this district was served with a printed interrogation requiring a listed return of tax-liable securities. The results of this campaign were embodied in the increased basis of 1902, 1903, and 1904.

Since 1903 there has been comparative inactivity on the part of the Appeal Tax Court in the matter of assessing securities, or at least no systematic endeavor to maintain a continuing revision of present accounts. Vigilance has been shown in scheduling notorious individual cases, which for some reason or other have here

tofore escaped. No small ingenuity has been displayed in tracing distributed estates or acquired capital or new issues of corporate obligations. After much effort the Supreme Bench has afforded access to its trust docket and to inventories of the Orphans' Court, and in other ways the basis has been materially enlarged. But the fact still remains that since 1898, with the exception of the rescheduling activity of 1901-03, itself partial and limited, there has been no systematic reassessment and no continuous revision in Baltimore of intangible wealth.

By this is not meant an endeavor to "drag the ponds" or to go through Baltimore with a fine-tooth comb, with a view to obtaining the listed return of every single bond or scrap of taxable stock. Such a procedure is manifestly Utopian in result, and the mere effort to realize it would mean a costly and offensive inquisition that would be repudiated after the briefest trial. It is the conspicuous absence of something very much less than this extreme procedure that is here noted. In consequence of an insufficient assessing force, it has been impossible to bring upon the tax books and to keep there, in reasonably close correspondence to actual values, anything like the aggregate volume of stocks and bonds which are now liable to taxation for local purposes at a rate commensurate with their income-producing capacity.

Within the last few months the municipality has awakened in some degree to a recognition of what may be accomplished in this direction. Additions have been made to the tax-assessing force for 1908, and a disposition has been shown to put into actual effect the provision of the city charter whereby every property assessment of Baltimore, whether real or personal, shall be subject to revision at least once in five years. If this new policy be carried into operation and if fidelity and

intelligence be displayed in its execution, the most favorable developments are to be anticipated.

V.

The situation might be summed up briefly as follows: the results obtained have been absolutely substantial, and relatively favorable, but they are very far from representing maximum possibilities. During the decade under consideration, Baltimore-the only city of size and wealth in the state-suffered a devastating conflagration, involving the destruction of many millions of tangible property and the necessary liquidation and conversion of considerable holdings of securities. The whole system of capital holding was disorganized, and only during the last two years has anything like equilibrium returned.

Moreover, the administration of the tax leaves much to be desired, both on the score of activity and efficiency. The whole basis of securities now upon the tax books, exclusive of the original listing, represents little more than the spasmodic efforts of an inadequate force working upon the problem at hand, under intelligent direction, but without systematic plan in pursuit. Beyond question better results are attainable. Any conceivable kind of tax would work poorly if similarly handicapped in administration. That under these conditions the results have been so favorable confirms the fiscal possibilities of the system under effective administration.

While the returns from the standpoint of the city's treasury have thus been far from satisfactory, the operation of the law has met with as much and as little favor at the hands of security holders as any form of personal taxation may expect to receive. That it is preferred to the old farcical endeavor to subject all such

property to the full city rate goes without saying. That it is deemed a not unfair distribution of the municipal burden is perhaps too much to state. All things considered, there seems a reasonable content, based in part upon appreciation of its necessity, in part upon fear lest it might be replaced by a worse substitute.

Whatever timidity operates to prevent a fuller return of securities seems to be inspired less by dissatisfaction with the burden of the present rate than the concern lest, when such property has been once assessed, the flat rate be repealed and the full city rate be imposed. In confirmation of this anxiety the well-known example of Connecticut in dealing with a somewhat similar device has been exploited. But, on the other hand, public sentiment seems to be crystallizing not only in favor of the tax as now imposed, but even to the point of recognizing that a breach of faith, or certainly a departure from sound policy, would be involved in any such change. At this juncture such a change is so remote as not even to be bruited, and from year to year, as the tax becomes more firmly intrenched and its results more favorable, the chance of any such course is likely to grow even less.

In short, there is no serious dissatisfaction with the operation of the device on the part of those directly affected, and there is expectation that, by keying up the whole tone of municipal tax assessment, substantially better things can hereafter be achieved for the city's interest. Subsequent experience may reveal defects or fallacies not now evident, but, if such be the case, amendment or repeal is entirely practicable. Considered as nothing more than a piece of fiscal opportunism, the Maryland device can properly engage the attention of those similarly circumstanced communities which are convinced of the unwisdom of further blunderbuss attempts to assess intangible wealth for full property taxa

tion, and yet are not prepared to go to the other extreme of complete exemption. To these the method herein briefly described has, to the limited extent of its application, at least the merits of reasonableness in theory and a fair amount of success in practise.

JACOB H. HOLLANDER.

JOHNS HOPKINS UNIVERSITY.