180 MISC. PUBLICATION 218, U. S. DEPT. OF AGRICULTURE 
difficulty of selling tax certificates to private buyers have emphasized 
the need for well-defined delinquent-land policies, including clear-cut 
and rigid procedure as to redemption or foreclosure, and proper dis- 
position of tax-reverted lands. Several States have finally so revised 
their tax laws as to guarantee clear title to tax-reverted lands and 
have also made some provision for administering such lands in the 
public interest. Notable among such States are New York and Mich- 
igan. The discussion of reversion in these two States thus includes 
a fuller historical statement than is attempted for the other States 
mentioned in this section. 
NEW YORK 
Prior to 1885 large areas of forest land in the Adirondack and Cats- 
kill Mountain regions of New York became delinquent for taxes and 
were bid in by the State. In that year a policy was established of 
creating State forest reservations in those regions by purchase, using 
as a nucleus some 600,000 acres of State tax-title lands. The tax 
laws of the State, however, were so worded and so construed by the 
courts that the State found it practically impossible to retain title to 
these lands against any private claimant, no matter how flimsy the 
claim. 
To remedy this situation, a law was passed in 1885 ® by which, in 
forest-preserve counties, absolute title was guaranteed after tax-sale 
conveyances had been on record for 2 years, which would be 4 years 
after the sale of the land. By this law the conveyance, after the 
lapse of a period of 6 months from the passage of the act, was taken 
as conclusive evidence of regularity of all procedure. In 1897 the 
validity of the act was sustained by the United States Supreme Court * 
In 1890 a second law was passed, by which the right of redemption 
expired 5 years from date of sale. The constitutionality of this 
statute has also been sustained. Thus tax-title lands in the forest- 
preserve counties pass directly to the State and absolute title is as- 
sured. In other parts of the State delinquent lands go to the coun- 
ties. 
The Hewitt Reforestation Act of 1929 authorized the purchase and 
reforestation of idle and abandoned land outside the forest-preserve 
counties by the State wherever blocks of 500 acres or more can be 
acquired, and by the State in cooperation with the counties in which 
they lie in the case of smaller abandoned tracts. An initial appropria- 
tion of $100,000 was provided by the act to inaugurate the work, and 
in 1931 the voters of the State approved a bond issue of $19,000,000 
to carry it forward. New York thus offers the owner of submarginal 
land an opportunity to sell it at a nominal price rather than have it 
confiscated through the process of delinquency. 
MICHIGAN 
The removal of timber values from many counties in north-central 
Michigan and the subsequent failure of agricultural colonization on 
land unsuited for farming precipitated a serious delinquency problem 
in that State as early as 1880-90. Unredeemed lands came back to 
the State in great quantities after 1896. A law of 1901 provided that 
these lands might be sold as well as homesteaded, as previously. In 
~ 68 New York Session Laws, 1885. 
64 Turner v. New York, 168 U.S. 90. 
6’ Michigan, Public Acis, 1901, Act 141. 
