be said to be ultimately spread over the community. There are, on the other hand, many taxes which do not lead to this phenomena and some taxes which are not shifted at all. A distinction must furthermore be observed between capitalization and shifting. If a tax is shifted, it cannot be capitalized; if it is capitalized, it cannot be shifted. There are certain conditions which predispose to the shifting of taxation. The more general a tax is the less likely is it to be shifted because the smaller the tax the less the field to which the individual can betake himself. Where commodities are produced under varying conditions, much depends upon whether the tax is imposed upon the marginal or the intra-marginal producer. Where a tax is imposed upon land which produced a commodity with a local market, the tendency is for the tax to be shifted to the consumer. If the tax is imposed on the North Dakota farmer whose wheat is sold in Liverpool, the shifting of the tax depends upon the relative cost of producing Argentine or Russian wheat and upon the existence or absence of equal taxes in those countries. Where a tax is imposed not upon commodities or property in particular, but upon profits or income in general, the tendency to shift is much less pronounced. With taxes upon a particular kind of commodity or upon a particular kind of income, the situation is different.

The shifting of the tax is of importance not only as between producer and consumer, but also as between borrower and lender. In taxes imposed upon mortgages or upon funds borrowed the incidence of the tax depends to a large extent on whether the tax is general or exclusive. If the tax is levied as a part of a general income tax, it will not be shifted; if, however, it is an exclusive or unequal tax, either by law or in actual operation, the tax will ordinarily be shifted from the borrower to the lender. A complete study of the shifting of taxation would involve a treatise on the formation and distribution of wealth.

The

Principles of Taxation.-There are four different sets of principles of taxation, fiscal, administrative, economic and ethical. fiscal principles are those of adequacy and elasticity. Unless a tax is sufficient to bring in the revenue that is needed or expected, it cannot be pronounced successful. Again, unless a tax is so elastic as to respond to the varying changes in economic conditions, it is also to be deprecated. The administrative principles of taxation are those of certainty, of convenience and of econoiny. Unless a tax law is certain in its provisions, it is a bad law. There is a great difference, for instance, between the certainty of a land tax and the uncertainty of a comprehensive or of a complicated income tax. The principle of convenience of taxation includes the question of how the tax is to be paid, when it is to be paid, where it is to be paid, and under what conditions, inquisitorial or otherwise, it is to be paid. The economy of taxation implies that a tax should take out of the pocket of the people as little as possible above what it brings into the government, or, in other words, that the cost of collection should be low. The economic principles of taxation may be declared to be innocuity and efficiency. The innocuity

or harmlessness of a tax is a most desirable attribute. All taxes, indeed, represent a burden but, as has been pointed out above, certain taxes have a far more destructive effect than others. Other things being equal, the legislator must chose the most innocuous tax. By the efficiency of taxation is meant the capacity of a tax to accomplish the desired result. Many a tax is admirable in other respects, but can be made to work in practice only with difficulty. The present property tax, for instance, in the United States is to-day no longer an efficient tax. The ethical principles of taxation are those of uniformity and universality. As these are the most important, they will be discussed separately.

Uniformity or Equality of Taxation.By equality is of course not meant absolute numerical equality, but relatively proportional equality. Uniformity, in other words, means relative uniformity. The question then arises as to the relation involved. To what should taxes be relative, in order to be equal? In former times the answer was that the real basis of taxation should be either the cost of service to the government or the value of the service to the individual. The more modern theory maintains that taxes should be in some relation to the faculty or the ability of the individual to pay. Much time has been spent upon the problem of what constituted the real elements of faculty. For a long time faculty was stated in terms of sacrifice. By equality of taxation there is meant an equality in the sacrifice imposed upon the individual. In more recent times, however, emphasis has been put upon another aspect of the problem. Sacrifice has to deal with the phenomenon of parting with one's wealth. It involves the question of what is left for immediate consumption after the tax has been paid. But economic life deals not only with consumption, but with production. When we come to consider the production of wealth rather than the consumption of wealth we are confronted by the facts of opportunity or privilege in the amassing of wealth. A man's ability to pay a tax, therefore, must be considered not only from the point of view of consumption but from that of production. In other words, the two elements of faculty are privilege and sacrifice: the easier it is for a man to make his money, the more ability he has to pay taxes; the harder it is for a man to be deprived of his money, the less ability he has to pay taxes.

The Norm of Taxation.-By the norm of taxation is meant the test of faculty. There have been no less than five such tests disclosed in the history of taxation: (1) The first test of faculty was polls. Everyone was supposed to have an equal ability to pay. In a primitive form of society the poll tax was legitimate. It has virtually disappeared to-day except in a few democratic communities like the United States, where it still lingers as a survival of a former and more primitive equality. (2) Expenditure. The advantage of expenditure as a test is that no one can escape because everyone spends something. The disadvantage of expenditure as a sole test of faculty is that some people must spend all they make, while others can save most of what they make. Expenditure thus becomes an increasingly unsatis

factory test of faculty; (3) Property. In a comparatively early form of society wealth in terms of property is an excellent test of faculty. The general property tax is accordingly found everywhere at a certain stage of development. The more complicated and the more differentiated the society, the more apparent, however, are the shortcomings of this test. The chief modern defects of property as a test of equality in taxation are the following: (a) While it is generally true that capital is nothing but capitalized income, there is in modern times frequently a discrepancy between the property and the yield or produce of the property. This may be due to speculation, to chance or to other accidents of economic life; (b) In modern times more and more wealth is derived from personal earnings rather than from property. The property tax would hit the owner of a $10,000 farm but leave untaxed the recipient of a $100,000 professional income; (c) There is a great difference between the legal and economic concept of property. Economically a man's wealth measured in terms of capital is his surplus over debts. Legally, property is independent of the debts. I may own a $10,000 farm even though I have borrowed $8,000 on the farm. The property tax frequently fails to make allowance for debts; (d) The concept of property fails to distinguish between consumption and production property. The property tax makes no distinction between the lawyer's library which contributes to his income and a bibliophile's library which may be a source of expense. 4. Product. The difficulties with the concept of property as a test of faculty led to the substitution of yield or produce as the proper test. Almost everywhere at a certain time the general property tax on the individual was, therefore, replaced by a series of taxes on the things themselves, measured by their product. Instead of a general property tax we now find a land tax, a capital tax, a business tax, a wage tax, etc. Produce is in some respects a more satisfactory test of faculty than property: it gets closer to the realities. But in the course of time a weakness disclosed itself in that not enough attention could be paid to the individual conditions of the recipient of the produce. 5. Income. The modern world has, therefore, come in large measure to an acceptance of the fifth test of faculty; which is that of income rather than of property or of produce. The tendency is accordingly strong for the replacement of the older taxes by modern taxes on individual income and business profits.

Graduated Taxation.-A further refinement, however, of the idea of faculty is seen in the growth of graduated or progressive taxation. Proportional taxation is giving way to graduated or progressive taxation because of the realization of the fact that graduation, although a technical breach of uniformity, really involves higher uniformity. Progressive taxation is now almost everywhere recognized even in American jurisprudence, as involving no inequality of taxation. A graduated tax is a tax the rate of which increases with every unit of the base. The entering wedge of the theory of progress in taxation is found in the minimum-of-subsistence doctrine, the doctrine, namely, that a certain amount of income should

be exempt from taxation because that minimum is indispensable to existence. This wedge was soon pushed further in so that emphasis was placed upon the element of sacrifice. The sacrifice involved in taking by taxation $100 from a man with a $1,000 income was recognized to be far greater than the sacrifice involved in taking $10,000 from the man with a $100,000 income. In one case the tax trenches upon the necessities and in the other it affects only superfluities. After some time, however, the conception of sacrifice was re-enforced by that of privilege. The difficulty of making the first $1,000 of a man's fortune is far greater than that of making subsequent accretions. All modern democracies are accordingly fast developing graduated or progressive taxes.

Differentiated Taxation.— The principle of faculty in taxation results not only in graduated taxation but in what is called differentiated taxation. Graduated taxation implies a change in the rate according to the amount of the income of property; differentiated taxation implies a change in the rate according to the kind of income of the property. The chief example of differentiated taxation is the distinction between what Great Britain calls earned and unearned incomes, i.e., taxation from property at a higher rate than income from labor. Other countries, however, like Italy, pursue the idea somewhat further and distinguish between property incomes, mixed incomes and labor incomes,-mixed incomes being incomes from business where both capital and enterprise are needed. The Federal income tax of the United States embodies the principle of graduated taxation, but has not yet accepted that of differentiated taxation. Where the distinction is made in the property tax rather than in the income tax, we are in the habit of calling it classification of taxation rather than differentiation of taxation. The movement for a classified property tax in lieu of the general property tax is making great headway in the United States. Classification for purposes of taxation has been upheld by the United States Supreme Court as involving no derogation from the constitutional principle of uniformity or equality of taxation.

Principle of Universality. The other outcome of the doctrine of faculty is universality of taxation. Equality of taxation means among other things that all people should bear their burdens; that everyone should be taxed, and that no one, in contradistinction to his neighbor, should be taxed more than once. The modern world permits exemptions from taxation, but modern exemptions are different from those of former times. The mediæval exemptions were class exemptions and were, therefore, reprehensible. Modern exemptions rest upon presumed lack of ability to pay or upon considerations of public policy. They are permitted, not primarily for the benefit of the individual, but for the benefit of the community. While, with the exception of these justifiable exemptions, everyone should be taxed, it is equally important to avoid double taxation. Double taxation, or duplicate taxation, is of two kinds. It may be imposed by the same jurisdiction or by competing jurisdictions. example of double taxation by the same jurisdiction is the simultaneous taxation of property

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and income. Ordinarily, to tax property is virtually to tax the income of the property. To tax the income again will then be double taxation. Where the purpose is to distinguish between earned or unearned incomes or to secure differentiation of taxation, where, in other words, the design is to tax property incomes more than other incomes, this form of double taxation is legitimate. Another example of double taxation is to tax the corporation and also the shareholder or to tax both the property and the mortgage on the property, because under the ordinary conditions of American life a tax on the lender will be shifted to the borrower so that the borrower will pay the tax not only on his own property but on that of the lender. Double taxation by competing jurisdictions is found when the same individual or piece of property is simultaneously taxed by different jurisdictions. An Englishman receiving his income from an American business may be taxed in the United States because the income is earned there; and taxed in Great Britain because he resides there. An American who dies in one State owning railway shares deposited with a trust company in another State, the chief office of the railway being in a third State and the railway line itself running through a fourth State, may conceivably be subject to taxation on the same property in all four States. The avoidance of such double or multiple taxation is possible either, on the one hand, by international agreement or the exercise of interstate comity or, on the other hand, as in some federal governments, by a federal law or ruling which apportions the tax among several states according to equitable principles.

Classification of Taxes.-There are many different ways in which taxes can be classified, according to the criterion employed. If emphasis is put upon property in which taxes are paid, we have taxes in kind and taxes in money. If the criterion is frequency of payment, they may be classified in terms of ordinary and extraordinary taxes. If the criterion is the rate of taxation, we may distinguish between apportioned and percentage taxes. A percentage tax is a tax like the income tax where the rate or percentage is known in advance; an apportioned tax is a tax like the real estate tax in the United States where the rate is arrived at as the result of an apportionment. According to the mode of levy, we may distinguish between taxes on persons and taxes on things. According to the method of measurement we may distinguish between assessed and expenditure taxes or between taxes on acquisition, on possession or on consumption. According to the methods and results of payment we may distinguish between direct and indirect taxes. This distinction is not very exact. It originated in the idea that where the taxpayer and the taxbearer were the same individual, the tax was a direct tax and, if they were different individuals, it was an indirect tax. The difficulty with this, however, is that the individual who would ordinarily transfer a commodity to someone else might consume it himself. The suggestion was, therefore, made to relegate the distinction to the intention of the legislator. Here again, however, we are met with the fact that the legislator frequently has no intention in the matter or that his in

tention is unknown. Some European writers, therefore, have contended that the criterion should be found in the permanence of the tax. If the tax is a recurring tax or if the phenomenon on which the tax is imposed is recurring, it is indirect, otherwise it is direct. In general, however, it may be said that by direct taxes are meant taxes on pollo, property or income, and by indirect taxes are meant taxes on consumption and on transactions.

The American Tax System.- The American tax system is composed of two elements -the State and local system and the Federal system. The State and local system has gone through several stages. At the end of the 18th century the slight revenue that was needed by the States and localities was derived chiefly from fees, together with poll taxes, taxes on land and taxes on a few articles of personal property. The land taxes were levied first according to quantity, then on gross produce or location and finally according to selling value. The separate property taxes gradually developed into a general property tax, which became the chief source of State and local revenue — the State tax being added to the local tax before the annual rate of taxation was determined. With the progress of society and especially with the growth of intangible personalty, personal property slowly slipped out of the assessment lists, so that the general property tax again became in fact, if not in law, a real property tax in great measure. This led, in the third quarter of the century, to an attempt to tax personal property through special taxes on certain corporations. Toward the close of the century the corporation taxes were supplemented by inheritance taxes. In several States liquor license taxes were added. Only in the Southern States do we also find a system of business or occupation or so-called privilege tax, as a survival of the Slavery system, where the plantation owners attempted to roll off the taxes on urban occupation.

The addition of corporation and inheritance taxes did not entirely solve the problem of the personal property tax. A two-fold movement accordingly developed in the 20th century. On the one hand we find the tendency toward the classified property tax, with lower rates for certain classes of personalty like money, securities, mortgages, etc. On the other hand came the movement for the replacement of the personal property tax by the income tax. Wisconsin took the lead in 1911, Massachusetts followed in part in 1915 and New York imposed a corporate income tax in 1916 and a personal income tax in 1919. Several other States have followed their example. The trend is now strongly toward a system whereby real estate will be taxed for local purposes and the State revenues be derived from an income tax, an inheritance tax and a corporation tax, part of the proceeds of which will be distributed to the local divisions.

The Federal tax system has also gone through several stages. At the beginning the Federal revenues were derived from import duties as well as from a variety of internal excises - including for a short time also a direct tax on land and on slaves. The advent to power of the Anti-Federalists in 1802 caused an abandonment of the so-called internal reve

nue taxes. From that year until the Civil War the sole reliance of the government was on import duties, except during the period of the war with England when the internal revenue taxes were restored. Shortly after the outbreak of the Civil War a comprehensive system of internal revenue taxes was initiated. These were abandoned one by one after the close of the war until only the taxes on tobacco and liquor remained. This system of import duties together with a few internal excises existed, with a slight interruption during the Spanish War, until 1909. In that year began the fourth period the supplementing of the tariff by direct as well as by indirect internal taxes. First came the corporation tax in 1909, then the income tax in 1913. With the advent of the World War, finally, there came not only the reintroduction of many indirect internal taxes but also the inheritance tax and the excess profits tax as well as taxes on expenditure. Of these the two former are likely to remain permanently.

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Thus while the land tax will continue to be levied primarily by the States, while import duties can be imposed only by the Federal government, and while internal taxes on modities will probably be reserved more or less exclusively by the Federal government, the income tax, the inheritance tax, the business or excess profits tax and the corporation tax will probably be imposed by both Federal and State governments. The great problem of the future will thus be the fiscal relation of State and Nation.

Bibliography.-Adams, H. C., 'The Science of Finance (New York 1899); Plehn, C. C., 'Introduction to the Science of Finance' (New York 1910); Bullock, C. J., Readings in Public Finance) (New York 1908); Seligman, E. R. A., Essays in Taxation' (8th ed., New York 1913); id., The Shifting and Incidence of Taxation (3d ed., New York 1910); id., Progressive Taxation in Theory and Practice' (2d ed., New York 1908); id., The Income Tax' (2d ed., New York 1914); Weston, S. J., Justice in Taxation' (New York 1905); Lutz, S. J., State Tax Commissions' (New York 1918); Proceedings of the National Tax Association (New York 1907-20); Bastable, C. F., Public Finance' (3d ed., London 1903); Stamp, C. A., The Income Tax' (London 1915); Cannan, E., The History of Local Taxation (2d ed., London_1912).

EDWIN R. A. SELIGMAN, McVickar Professor of Political Economy and Finance, Columbia University.

TAXIDERMY is the art of stuffing and mounting the skins of animals, or their heads, so as to appear natural and lifelike. It is no longer a question of filling out a skin, but rather of making a statue of a creature long since dead, which will exactly fit the skin of that particular creature, stand erect and pose as the counterpart of life. "Taxidermy, the handmaid of zoology," said Dr. J. A. Allen, "has already become one of the fine arts, requiring the skill and other qualities of both the sculptor and the painter, and capable of yielding results comparable with the masterpieces of either." It is, however, one of the newest of the arts, and there is serious need of a well-established school of taxidermy in connection with some

one of our great museums. Prior to 1880 only one American museum (the National) maintained a corps of taxidermists, and the majority of the mounted birds and mammals which found their way into other American museums were mounted at Ward's Natural Science Establishment, by men from France and Germany. Methods were crude and results were far below the standards attained a few years later. Much of the work produced prior to 1880 has since been either dismounted and remounted or else destroyed.

In March 1880, at Ward's establishment in Rochester, N. Y., Messrs. Hornaday, Webster, Lucas, Martens, Bailly, Critchley and Fraine organized the National Society of American Taxidermists and seriously began the task of developing taxidermy up to the level of the fine arts. All jealousy and exclusiveness were swept aside and the three competitive exhibitions that were held in Rochester, Boston and New York finally opened the eyes of scientific men and of the general public also to the possibilities of scholarly taxidermy, when properly encouraged and paid for. The upward impetus then gained has already carried American taxidermy beyond the original hopes of the founders of the society and the museums of America are now being filled with mounted vertebrates that in large measure are not only of real educational value but are also agreeable to the eye. No modern American museum is now complete without a well-equipped department of taxidermy, in charge of a chief taxidermist on a salary, which in 1880 would have been considered unattainable.

In a modern, high-class taxidermist, the first requisite is not a knowledge of methods in mounting, but the thorough education of the eye in animal forms and expressions. This must be secured by courses in drawing, modeling, carving and painting. The skeletons and external muscles of animals must be well studied, the latter from life. Besides the making of numberless sketches from life, hundreds of live-animal photographs should be collected and arranged for reference. Casts of heads and special parts of dead animals are of great importance and should be diligently collected. At all times must the natural history of the vertebrates be studied and kept in mind. When this preparatory work has been accomplished the aspirant for taxidermic honors must secure admission to the laboratory of some mastertaxidermist and work with him to acquire a knowledge of methods.

A comparison of American with European taxidermy is of but passing interest, chiefly for the reason that without an international exhibition it is impossible to draw parallels of positive value. From three inspections of European zoological museums, made in 1876. 1896 and 1902, it is the opinion of the writer that the best of our museum taxidermy is now decidedly in advance of the best to be found in Europe. The groups of mammals, great and small, that now are so intensely interesting to visitors in the museums of Washington, New York, Pittsburgh, Chicago, Milwaukee and at the University of Kansas, have no counterparts in Europe. The British Museum of Natural History at South Kensington contains a fine series of groups of birds, mounted with natural

accessories. In the museum of the Amsterdam "Natura Artis Magistra," there are a number of excellent groups of birds. In the museums of the American cities mentioned above the huge family groups representing the bison, moose, elk, caribou, musk-ox, deer, antelope, eland, zebra and other animals, all provided with carefully-studied natural accessories, constitute enduring monuments to the skill of American taxidermists.

Of all museum officers who have actively promoted the development of American taxidermy, Prof. Spencer F. Baird and Dr. G. Brown Goode stand first. As early as 1880 they advocated the attainment of perfection in results, regardless of time or cost. It was by their consent and co-operation that the National Museum set the pace in the development of large groups of mammals, which really began in 1887 with the group of American bison. In this connection honorable mention is due Prof. Henry A. Ward, founder of Ward's Natural Science Establishment, for the far-reaching influence exerted by him for the improvement of taxidermic methods generally and the COoperation which he extended to the Society of American Taxidermists.

With the improvements noted in museum taxidermy, equal advances have been made in the class of what is known as custom taxidermy. The number of trophy heads of large mammals that are now mounted annually in the United States cannot be less than about 1,800. About two-thirds are heads of deer and the remainder consist of moose, mountain-sheep, caribou, elk, antelope, mountain-goat, buffalo, musk-ox and bear, about in the order named. Twenty-five years ago a finely-mounted head was a rarity, but to-day, outside of the workshops of amateurs, a badly-mounted head is seldom seen. The standards of excellence have risen very greatly. The demands of patrons are more intelligent and good work is better compensated than heretofore.

As the world's mammals, birds and other vertebrates decrease, museums multiply, and the desire to provide fine collections becomes more earnest and insistent. Taxidermy now offers a good field for a limited number of young men of real artistic instincts who can bring to it adequate education and training and unlimited capacity for hard work.

Some important American works on taxidermy should be enumerated: Hornaday, 'Taxidermy and Zoological Collecting' (1892); Davie, 'Methods in the Art of Taxidermy' (1894); Rowley, Art of Taxidermy) (1900); Reed, C. K., Guide to Taxidermy' (Worcester 1908).

W. T. HORNADAY,

Director New York Zoological Park. TAXING DISTRICT. See DISTRICT. TAXONOMY IN PLANTS, derived from the Greek words ragiç taxis, meaning arrangement, and voμos, nomos, law. Called sometimes taxology. It is the study of classification, especially from a biological aspect, and treating of the morphology of plant life. Ray (1703) divided the vegetable kingdom into two general classes: the Flowering and the Flowerless, basing everything on one single characteristic. Endlicher, a little over a century later,

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formed the plant world into two groups: Cormophyta and Thallophyta, but the division was very imperfect and overlapping. Later we find two groupings by Linnæus under the titles: Phanerogamia and Cryptogamia, the former having flowers with stamens and pistils, the latter flowerless, seedless and propagated by spores. But the designation Cryptogamia, still retained by a few, their generative method being no longer cryptic (occult) or hidden from our present advanced knowledge. Thallophyta, still remaining in general use, no longer describes the class formerly considered by the expression. Thus with ever-increasing knowledge of the life-workings of the plant realm bringing new facts we have had to change repeatedly the system in taxonomy to bring the additional facts into close relation. And so the system of Ray gave way to the Endlicher, the latter to the greatly improved system of Linnæus (1735) with its 24 classes divided according to the number and disposition of the stamens, with variant orders according to the number of styles or stigmas, etc. This method of systematization, proving its deficiencies ever more with a deeper investigation of plant nature, had to give way (1813) to the Candolle system, soon to be displaced by the Sachs method of classification with its seven divisions, Protophyta, Zygophyta, Oophyta, Carpophyta, Bryophyta, Pteridophyta, Phanerogamia. The Sachs system is much in use to this day, but the most recent classification of botanists, based on the great advances brought about by microscopic and other researches into the plant structure, which keep disclosing weaknesses of the former system, are the following four main classifying divisions: (1) Thallophyta; (2) Bryophyta, (3) Pteridophyta; (4) Spermaphyta. The first three belong to the Cryptograms, the latter to the Phanerogams. It is an improvement generally considered better suited to the enlarged range of the botanist's vision; but already criticism is creeping in and taxonomy in plants may be subjected soon authoritatively to a further revision.

(1) Thallophyta. This division includes all of the four primary classes, the uni-cellular organic growth, having root, stem and leaf undefined. Under this head come the algæ, fungi, bacteria and lichens. (See BOTANY). (2) Bryophyta. These include the mosses and liverworts (hepatica), with distinct sexual organs in some, but in this division (as above stated) is the liverwort and other plants of the thallus type. (See BRYOPHYLLUM). (3) Pteridophyta. These are often termed vascular cryptogams and include, chiefly, the ferns with their propagation by spores. Their stem, leaf and root are clearly defined. (See PTERIDOPHYTA). (4) Spermophyta or Phanerogams. These are lately being divided into angiosperms and gymnosperms and the angiosperms are subdivided into dicotyledons and monocotyledons. The Spermophyta are the highest division of plants including those having true flowers and seeds. They are for the most part land plants, while many of the former divisions are aquatic. Their female cell (oospore) is fertilized in propagation and, protected by the ovule, becomes a seed, the seed formation being the characteristic of this group (termed also seed