PRINCIPLES OF TAXATION. 357 



erty of a visible character, as slaves, horses, and cattle, and to 

 exempt from taxation debts, accounts, merchandise,* and all other 

 items susceptible of concealment, and which would necessitate 

 inquisitorial methods for assessment. And it was not until 1847, 

 when the State had become financially embarrassed by large expendi- 

 tures, that any change was made in such system. But in later days, 

 when laws came to be made by legislators who could not conceive 

 that anything more was involved in taxation than the raising of a 

 given amount of money, the discriminating rule in respect to the situs 

 of real and personal property was generally adopted and has resulted 

 in the before-mentioned absurdities. Another involved absurdity is 

 that those States which adopt in their systems of taxation the rule of 



* In a report of the law committee of the Common Council of the city of Philadelphia, 

 submitted February 16, 1871, we find the following historical review of the tax laws of 

 Philadelphia, under the government of William Penn and his successors in the colonial 

 government : 



" These laws were framed to avoid repeating errors (in respect to the taxation of per- 

 sonal property) which had been proved by long experience in Great Britain and the Con- 

 tinental countries to be inquisitorial in their nature, and by concealment, evasion, and per- 

 jury demoralizing to the people. We find the Provincial Council (1683) first determining 

 that ' a publick tax on land ought to be raised to defray the publick charge,' and the 

 enactment of 1700, fixing county rates and levies (which law was not enrolled), is believed 

 to have been not larger in the subjects of county rates than in the act of 1724, which were 

 real estate, horses, cattle, sheep, negroes, and a poll tax. It will be noticed that the per- 

 sonal estate here enumerated was visible property not susceptible of concealment, and that 

 debts, accounts, merchandise, and ships are nowhere mentioned. In the several enact- 

 ments that followed in 1795, 1799, and 1834, the subjects of county levy were substantially 

 the same, sheep and slaves being omitted in the last act, and officers added to the last two, 

 and it was not until 1844, a period when the State, by large expenditures, had become em- 

 barrassed, that, by the act of 29th day of April, 1844, mortgages, money owing by solvent 

 debtors, stocks, household furniture, public loans, watches, etc., were made taxable for 

 county purposes. The attempted enforcement of this act was so injurious to the people, by 

 driving capital and industrial establishments from the State, and so evaded in returns, that 

 by common consent the law remained on the statute book a dead letter until the consolida- 

 tion of the city. 



"At that time (1854) the question was again discussed, and although the councils of the 

 city had the power to impose the tax rate upon all the subjects of taxation, in the thirty- 

 second section of the act of 1844 we find, by the first ordinances, they limited the levy to 

 real estate, furniture, horses, cattle, and pleasure carriages, and so continued until 1864, 

 when an act was passed empowering the city to levy taxes on all the subjects of taxation 

 contained in that section of the act of 1844, a power which they possessed before, but had 

 not exercised. 



" Since that time the authority of the city to levy a tax on mortgages, stocks of Penn- 

 sylvania corporations, and occupations, has been repealed. In considering the enlargement 

 of the subjects of levy in this city, the fact must not be lost sight of that the State does 

 not impose any tax on real estate for State purposes, but derives all its revenue from cor- 

 poration stocks and loans, mercantile license, tavern licenses, collateral inheritance, etc., 

 and it is estimated that of the gross receipts for 1870 ($6,336,603) more than two fifths of 

 the amount ($2,600,000) was derived from the property and business interests of the citi- 

 zens of this city." 



