renewed and the rate limitation act in force, but it was also apparent that the legislature would soon impose still further restrictions on the tax rate. Moreover, the assessment of public utilities and the equalization of the valuation of bank shares and of real estate was now entrusted to the tax commission. The combined result of these forces was a marked increase in the amount and valuation of all kinds of property on the tax duplicate. The assessments fixed in 1912 and 1913 are, however, a fairer test, because the tax limit law was then better understood. The subjoined table1 shows the percentile increases in the assessed valuation of various kinds of property over the valuations of 1910:

1 Tables I and II are derived from the following figures compiled from the Reports of the Auditor of State for 1910-12, and of the Tax Commission for 1910-13. The figures are not in entire agreement. I have used those given by the commission for public utilities and for banks in 1910, altho this figure may include bank realty. The figures for miscellaneous corporations, 1910-12, are arrived at by subtracting the valuations taken for banks and utilities from the amounts for incorporated companies. All intangible property of corporations which is separately stated by the auditor has been assigned to miscellaneous corporations. Finally, I have felt warranted in increasing the 1910 total for corporate personalty by the amount of the discrepancy in the auditor's statements.

PROPERTY VALUATIONS BY SPECIFIED CLASSES, 1910-1913
(Amounts in millions of dolllars)

It is apparent from the above table that the most noteworthy increases in taxable valuations have occurred in those fields in which the influence of the state tax commission has been strongest.1 In other words, the great additions to the grand duplicate of the state in the three years following 1910 are for the most part due to central assessment or equalization of the valuations of banks, public utilities and real estate, rather than to fuller returns of their property by tax-payers under the inducement of limited rates. Even in those cases where the assessment is based directly on the declaration of the tax-payer (individuals and miscellaneous corporations), improved assessment work, as previously noted, has contributed to the increase of valuations. Altho relatively much less than in the case of assessments definitely fixed by the tax commission, the increases in the valuations returned to county auditors and local assessors are yet considerable; within the three years

1 The discrepancies between the reports of the auditor and tax commission make it seem not improbable that these increases are too low in the case of banks. But the classification of corporate property is necessarily somewhat provisional.

2 The original valuation of real estate as fixed by the assessors in 1910 showed an increase of 126 per cent over the amount then on the duplicate; to this valuation the tax commission added nearly $500,000,000, or 25 per cent. See Report of the Tax Commission, 1911, Appendix.

the assessments charged against miscellaneous business corporations increased $295,000,000,1 those in respect of the tangible personalty of individuals increased $170,000,000, and those in respect of individually-owned intangible property increased $100,000,000.

The change in distribution of the tax burden among the owners of the various classes of property is, however, a more significant test of the results of the Smith law than the increase in valuations. Table II exhibits these changes.

TABLE II

PER CENT DISTRIBUTION OF PROPERTY, BY CLASSES, 1910-1913

The significant changes in the immediate incidence of the tax burden which are brought out by the table are the increase in the share of taxes falling upon public utilities from 9.1 per cent of the total in 1910 to 15.7 per cent in 1913, and the decline in the share borne by individuals, whether in respect of the ownership of tangible or of intangible property. The increase in the

1 The valuation of miscellaneous corporations appears to be very low, when compared with their returns to the commissioner of internal revenue. The figures are of course not strictly comparable; but miscellaneous corporations having their principal place of business in Ohio reported in 1914 a stock capitalization of $1,679,000,000 with taxable income of $196,500,000, which is 11.7 per cent on the capital. The property of miscellaneous corporations in Ohio was valued in 1913 at $455,800,000.

share of taxes falling upon public utilities is to be attributed mainly to the activity of the tax commission in correcting the gross under-assessment which had prevailed prior to 1910. By contrast with the increase in the share borne by public utilities, the decrease in the share of taxes falling upon miscellaneous corporations and individuals from 21 to 16.2 per cent emphasizes the failure of self-assessment even under limited tax rates. The cherished hope that limited rates would avail to place a juster share of the burdens of government upon the owners of intangible property has been sorely disappointed, for such property has of recent years formed a smaller proportion of all property on the duplicate than ever before. The amount of taxes assessed to individuals in respect of their ownership of intangible property, computed at the average tax rate prevailing in the state, was 36 per cent less in 1912, and 27 per cent less in 1913, than in 1910, altho within the period the total amount of taxes levied upon property was increasing.

We may next inquire whether the relative decline in the valuation of the personalty of individuals and miscellaneous corporations can be viewed with satisfaction, as representing merely an equalization of assessments, or whether there continues to be under-assessment and evasion in the assessment of these classes of property.

It is, of course, not possible to estimate the amount of taxable personalty owned by individuals. The total amount of certain classes of intangible property may indeed be approximated, but its ownership is an unsolved riddle. Nevertheless, certain comparisons may be instituted which will throw some light on the relative efficiency of the assessment of different sorts of property.

The entire amount of intangible property listed for taxation by individuals and miscellaneous corporations

in 1912 was $306,756,000, of which $119,202,000 represented "moneys on hand or on deposit subject to order." Ten days after tax-listing day, incorporated banks in Ohio reported individual demand deposits aggregating $357,735,000. At the same date these banks reported time deposits of $331,321,000, and during the year building and loan associations reported deposits of $57,468,000. On June 14, 1912, private banks reported to the comptroller demand deposits of $11,168,000, and other deposits of $13,088,000. Demand deposits therefore aggregated $368,903,000; time deposits, $401,877,000. Time deposits are, under a ruling of the attorney general, taxable as moneys if they are actually paid on demand; otherwise they are taxable as credits and may be offset by debts. Probably most of them are in strictness taxable as moneys. If so, the true amount of moneys approximated $770,000,000.1 A considerable portion of these deposits must have stood to the credit of public utility companies; but since it is improbable that such concerns carry any large amount of time deposits, it seems fair to conclude that their deposits could at most account for the demand deposits in excess of the amount of moneys returned. The amount of bank deposits in Ohio. which were legally taxable as moneys to individuals and miscellaneous corporations must therefore have been nearly $500,000,000.

The amount of other items of intangible propertycredits and investments - cannot be so readily estimated. Mortgages may be omitted from the estimate, because they are so largely held by banking institutions and insurance companies, and are thus taxed indirectly

The year 1912 is chosen for this comparison because the state department of banking issued no call in April, 1913. The returns of all classes of banks to the Comptroller of the Currency as of June 4, 1913, show deposits aggregating $821,331,000. The amount of moneys returned by individuals and miscellaneous corporations as of April 13, 1913, was $112,695,000, and the total amount of intangible property so returned was $301,537,000.