G4 MISC. PUBLICATION 218, U.S. DEPT. OF AGRICULTURE 
to the board of review or to the courts (38, pp. 1538-161). The pre- 
vailing practice of undervaluation by the assessor not only encourages 
an owner to omit filing the required statement but is also a direct 
obstacle to an effective appeal for review even if he does file. It is 
apparent that in a district where property is assessed on the average 
at 40 percent of true value, if a certain property is assessed at 80 
percent, its owner is entitled to relief, but all he can prove to the re- 
viewing body with reference to his own property is that it is assessed 
20 percent less than the law requires. Unless the reviewers know and 
are willing to recognize the actual situation, the owner is faced with 
proving that he has been discriminated against in comparison with the 
general level at which other properties of the same class are assessed, 
an impracticable procedure for the ordinary small taxpayer. A large 
taxpayer may protect himself through appeal to the courts, if he cares 
to risk incurring the enmity of the local tax authorities, since the right 
to an equitable assessment, even when equity means a much lower 
assessment than the full value prescribed by law, is recognized in a 
number of decisions of the Supreme Court of the United States, from 
among which the following ¥ is quoted: 
This Court holds that the right of the taxpayer whose property alone is taxed 
at 100 percent of its true value is to have his assessment reduced to the percentage 
of that value at which others are taxed even though this is a departure from the 
requirement of statute. This conclusion is based on the principle that where it is 
impossible to secure both the standard of the true value, and the uniformity and 
equality required by law, the latter requirement is to be preferred as the just 
and ultimate purpose of the law. 
The practices of the boards of review vary widely, from scarcely 
looking at the assessment rolls, to doing the work of the assessor in 
making the complete revision of the previous year’s roll (23, pp. 68, 
200-204; 35, p. 99; 41, p. 27). 
In Vermont, for one example, there is no way in which a reviewing 
board can act on its own motion to correct an abnormally low original 
valuation. This can be accomplished only by the appearance of an 
aggrieved taxpayer before the board of abatement, composed of the 
town assessors, which board can correct the appraisals which it itself 
previously made in its other capacity as a board of assessors. Then, 
if the aggrieved taxpayer is not satisfied, he can appeal to the board of 
civil authority, composed, in addition to the assessors, of the clerk, the 
three selectmen, and the justices. Further appeal is possible to a 
county board of appraisers appointed by the tax commission (80, 
p. 462). Seldom does a taxpayer make appeals to other than the 
first of these boards. 
EQUALIZATION 
ORGANIZATION 
The term ‘“‘equalization” is used in this report to denote an ad- 
justment of assessments as between assessment districts or groups of 
such districts. The functions of review and of equalization are often 
confused in taxation literature. Perhaps this may be due to the fact 
that in the counties of many States the board of review and the board 
of equalization are comprised of the same personnel. 
In some States, so-called ‘‘equalization”’ is accomplished by hori- 
zontal percentage increases or decreases in the assessment of every 
18 Sioux City Bridge Co. v. Dakota County, Nebd., 260 U.S. 441.. 
