fused rights of ownership, the
capital of individual stockholders and bondholders. Confused by this
ambiguity, the men of that time believed (as many still believe) that
there were here two separate and justly taxable funds of value. The
popular will declared (and still declares) that "all kinds of property
ought to bear their fair share of the burdens of taxation." Yet to
apply this principle would obviously be double taxation and result
in confiscation in many cases. Between this doubt and the practical
difficulty of assessment, it turned out that corporate wealth, far
from being doubly taxed, was largely escaping even its due single
burden.

Sec. 12. #Special taxes on banks.# Attempts to deal with the difficulty
without clear perception of its cause took the form of legislative
tinkering and patching. Taxes were gathered from corporations by any
device that seemed workable. The banks, being the earlier important
corporations, were first experimented upon. Taxes on capital stock and
on circulation were tried first (in 1805, by Georgia), then a tax on
dividends (in 1814, in Pennsylvania, and in 1815 in Ohio), examples
which were followed or modified by a number of states. After the
national banking system was started in 1864, attempts to tax both the
capital of the banks and the stock in the hands of individuals led to
federal court decisions and then to state legislation by which now in
many of the states the banks are separately taxed on their real estate
and the shares are assessed to the individual holders (by various
rules), but the taxes deducted from dividends and paid by the bank.
There are, besides, special franchise taxes and fees paid by banks in
various states.

Sec. 13. #Special taxes on insurance companies#. Insurance companies
present in a striking manner the complexities of the ambiguous
property concept. The assets of the insurance companies (we refer here
particularly to the reserve companies), which belong in equity to the
policy holders (less the claim of the stockholders in the case of
the stock companies), are nearly all invested in stocks and bonds of
corporations and in mortgages on real estate. Now under the general
property tax, strictly interpreted, the policies are assessable
at their surrender or reserve valuation in the hands of the policy
holders; secondly, the securities and credits which compose the assets
are assessable to the company; and, thirdly, the railroads, factories,
and hou