FOREST TAXATION IN THE UNITED STATES 453 
charged that the premium on the destruction of the forest has not 
been entirely removed, because the land value is usually closer to 
one-tenth of the total value than one-fourth, and because many 
owners would hesitate to commit themselves and ther heirs to the 
specified system of operation for 30 years. During that time in- 
heritance taxes or some other unusual charge might have to be met. 
Unless the forest had already been so heavily cut that it could in 
no case yie'd an income within the 30-year period for meeting such 
demands, it might be considered imprudent to assume the required 
ob igation. However, it is now admitted that, partly due to the 
exce lent relations between the forest owners and the personnel 
of the ‘orest service, this provision has been taken advantage of 
more genera ly than was at first anticipated (244, p. 474). 
So far nothing has been done to mitigate the unfortunate effect of 
the heavy inheritance taxes on forest properties. ‘The forest land- 
owners have made a number of proposals, none of which has been 
satisfactory to the ministry of finance, but it is understood that there 
is now (1933) a possibility of agreement. The formation of an 
advisory commission, including representatives of the forest owners, 
to assist in framing such legislation and pursuant regulations is under 
discussion (244, pp. 475-476). 
The forest owners have been placed in a somewhat better situation 
with respect to the registration taxes on transfers by a decision of the 
supreme court (la cour de cassation) issued October 28, 1931, affecting 
the valuation of forests for the purpose of these taxes. The finance 
officers had required a valuation based on the value of the soil plus 
the value of the trees for immediate realization. The court upheld 
the view that the value intended by law is that which is accepted by 
the general opinion, taking into account the nature of the property 
and the normal method of operation. It was not intended, according 
to this decision, that the valuation should contemplate the destructive 
exploitation of the forest or take into account the value to an owner 
for reasons of taste, family pride, personal interest, and the like. The 
appraisal approved by the court was based on the value of the soil 
determined directly by considering the quality of the land and the 
cost of reforestation, plus the value of the trees with full deduction 
of all the costs and expenses which would resuit from the acquisition 
itself, and from either the conservation and administration of the 
property after its acquisition or from its orderly liquidation (242). 
It has been proposed that perpetuation of private forests and 
continuity of management could be assured in spite of the inheritance 
taxes through the incorporation of private holdings in forest-manage- 
ment companies (244, pp. 478-479). Then if an heir had to raise 
money to meet inheritance taxes, he could sell some of his shares in the 
forest-management company without causing abnormal cutting of 
timber or otherwise disrupting the management plans. However, 
the various corporation taxes in France are so heavy that they shut 
off this avenue of escape. The schedular income tax alone would be 
doubled, since this is applied both to the income of the corporation 
and to the dividends paid to the stockholders. The property of such 
a corporation would also be subject to the taxe de mainmorte, a tax 
levied by the National Government on real estate which is held by 
corporations or associations so that it escapes transfer taxes. Since 
