100 MISC. PUBLICATION 218, U. S. DEPT. OF AGRICULTURE 
The objections to arbitration of assessments are many. It has 
been pointed out— 
that this privilege of arbitration detracts from the proper dignity and authority 
of administrative courts, that the arbitrators have no record of consistent action 
to maintain since most of them serve in only one case, and that appeals should 
look to the harmonizing of law and its administration, while under the method of 
arbitration a dozen cases which are appealed from one county board of assessors 
may be, and in all probability will be, decided by a dozen different groups of 
arbitrators (2, p. 19). 
The arbitration of assessments has been practiced in Mississippi but 
has proved to be unsatisfactory, as indicated in the following state- 
ment, which appeared in the report of the State tax commission of that 
State in 1928 and was repeated in the 1930 report: 
Section 10, chapter 323, laws of 1920 [repealed in 1930—editor’s note], provides 
that a taxpayer may appeal to a board of arbitration in case he is dissatisfied with 
his assessment. This law was enacted so that the small taxpayer could take an 
appeal without having to employ counsel or incur court expenses. In other 
words, it was intended to supply an inexpensive, simple method for the adjudica- 
tion of appeals by taxpayers having small assessments. So far as this office can 
ascertain, no appeal to a board of arbitration has been taken except by the largest 
taxpayers, and the result of these appeals has been uniformly in favor of the 
taxpayer. A statute, which was designed for the benefit and protection of the 
small taxpayer, has been used as an avenue of escape by the larger taxpayers 
(36, p. 200). 
COURT APPEAL 
The district courts and the State supreme courts are the last resorts 
open to individuals and assessment districts in appealing from an 
unjust assessment. In practice the courts are appealed to only in 
extraordinary cases because of the costs involved. And the only 
justification for an assessment determined by the court is an error on 
the part of the legal agencies for review and equalization. 
In 11 States (Connecticut, Idaho, Louisiana, Maine, Massachu- 
setts, Montana, Nevada, New Hampshire, Rhode Island, Utah, and 
West Virginia) the right of appeal from an unfair assessment is for- 
feited by noncompliance with the law requiring the taxpayer to file 
with the assessor a list of his property (38, pp. 153-161). In 1932, 
however, the Rhode Island Legislature gave taxpayers the right of 
appeal even though they had failed to file sworn statements of taxable 
property as required. 
PRINCIPLES OF VALUATION 
As has been previously observed, the chief task of assessment is to 
ascertain the value of taxable property. Critical analysis of the 
actual results of assessment requires a clear notion of the meaning of 
value as that term is employed in the property tax statutes. 
As already defined, the value of anything, in economic science, is 
the quantity of some other thing, usually money, that would be given 
in exchange forit. This will be recognized as agreeing about as closely 
as any precise definition can with the popular concept of value. The 
plain meaning of the tax statutes and the decisions of the courts 
indicate that, with few if any exceptions, the legislators of the several 
States had in mind essentially the concept of value as used in economic 
science. The legislatures have often gone out of their way to specify 
in the laws that property shall be assessed at its ‘“‘actual’’, ‘‘full’’, 
