COMPTROLLER OF THE TREASURY. 25

The taxes necessary to pay the interest on the remainder of the
public debt, for which no offset is available, would be a trifling matter
if so distributed as to be borne by all the wealth, capital and property
of the State. This debt having been contracted almost exclusively for
assistance to internal improvement Companies, it is right and proper
that these Companies should contribute largely to the taxes necessary
for the payment of the interest and principal so incurred for their
benefit. The justice and fairness of this proposition will hardly be
openly controverted. As I have heretofore said, the property interests
generally, have cheerfully borne the burdens of taxation for this pur-
pose, for a great number of years, until the success of many of these
enterprises has been established, and they have become wealthy and
powerful corporations. Other interests, the agricultural particularly,
have, from various untoward events, been impoverished and reduced,
and it seems fair and just that, as far as practicable, relief should now
be afforded by the great institutions, for the advancement of which
taxation has been so long borne. A safe conclusion, as to what partic-
ular method of taxation will most effectually and equitably reach these
companies, is attainable only by study and reflection.

After much attention to the 'Revenue Laws of other States, and
deliberation over the different methods of taxation, I am induced to
believe that the proper basis of taxation of Rail Road and Canal Com-
panies, and of all other Corporations other than Banks and purely
monetary institutions, (for State purposes.) should be their gross
receipts. These are capable of exact ascertainment and absolute cer-
tainty, and are not liable to evasion, and nothing but fraud or perjury
can render them intentionally uncertain or unintelligible.

Apart from the fact that provisions, for the exemptions of the
capital stock and property of our principal railroads from taxation, are
contained in their charters, and questions as to the right and power of
a subsequent Legislature to repeal those exemptions, may possibly
arise and produce delay and litigation; it is clear to me. that
neither the capital stock nor the property of railroads or canals is the-
proper basis of State taxation.

The property of railroads and canals may very properly be liable to-
county and muncipal taxation, but it is too uncertain, and frequently
too insignificant, to be relied upon to produce a proper revenue to
the State.

The rolling stock of a railroad, for instance, may be owned by some
other company than the one using it, frequently perhaps by a company
outside of the State, the termini of the road and its principal depots