"The inheritance tax in one form or another has come to stay, and new States are being added every year to the list of those which have adopted it. Five years ago it was found in only nine States of the Union--Pennsylvania, Maryland, Delaware, New York, West Virginia, Connecticut, Massachusetts, Tennessee, and New Jersey. During the first half of 1893 Ohio, Maine, California, and Michigan were added to the list, though the Michigan law was afterward annulled because of an unusual provision in the State Constitution which was not complied with. In 1894 Louisiana revived her former tax on foreign heirs; Minnesota adopted a constitutional amendment permitting a progressive inheritance tax which has not yet been given effect by the Legislature; and Ohio added to her collateral inheritance tax a progressive tax on direct successions. In 1895 progressive inheritance taxes were adopted in Illinois and Missouri, and an old proportional tax was revived in Virginia; and last year Iowa adopted in part the inheritance tax recommendation of her revenue commission."[52] [Footnote 52: Max West, in North American Review, May, 1897, p. 635.] The real problems are to be encountered in local taxation. The many different methods used in the different States, the want of uniformity in the local divisions of each State, and the extraordinary diversity in the interpretation or application of tax laws by the courts and executive authorities of the States have introduced a confusion, to end which, many would invoke the intervention of the Federal Government. The haphazard manner in which the laws have been framed and passed is only the least notable explanation of the variety of phrase and interpretation to be found. Even were the Federal Government to establish definitions, and frame rules of uniform assessment, there would still be room for difference. The customs tariff is known to be variously applied in the different ports of the country, and there is greater certainty in the tariff rate than could be found in a tax resting on the assessed valuation of land, for example.