This statement is not only inaccurate, but involves the other error of assuming that the appraisal figure was to be used for taxation. It was not. It was merely information to aid the legislature in framing new taxation laws. The chief error, however, is in assuming that Professor Adams added the value of the property, as determined by a capitalization of net earnings (which _per se_ is a well-recognized method of valuation), to the value of the physical property. This error probably is due to the flood of criticism which at the time was aimed at any form of non-physical valuation. Professor Adams finds the net earning in Mr. Hansel's example to be $1,000 per mile. From this, in the method actually used, he deducts an annuity for the support of invested capital, which he assumes to be the present value found by Professor Cooley. In the example given by Mr. Hansel he would deduct 4% on $15,000, or $600 per mile, leaving $400 per mile as surplus, or the earnings due to non-physical elements of value. This, capitalized at 5%, would give $8,000 per mile, which, added to Professor Cooley's figure of Present Value, would make $23,000 per mile, instead of $35,000, as stated by Mr. Hansel. The most recent criticism of the Michigan valuation work was in an address[15] before the New York Traffic Club in January, 1909, by Mr. W. H. Williams, Third Vice-President of the Delaware and Hudson Company. This address is devoted to an attack, not only on the work of the Michigan appraisal, but on Professor Adams' work and on the propriety of valuation work being undertaken for any reason. The arguments advanced in this address are such that a discussion of them becomes almost necessary in any complete review of the Michigan work, and it contains so many statements which are erroneous that it would hardly be permissible to pass them without comment. The manifest impatience with all forms of governmental interference with corporations, which so often characterizes the utterances of prominent railway officials, appears in this paper to a marked degree. After stating that the present agitation for a physical valuation appears to be the result of a misconception, on the part of the Interstate Commerce Commission, of Section 20 of the Act to Regulate Commerce, and quoting Professor Adams' suggestion of an inquiry, he says: "Subsequently, the desire of Governor Pingree to find a means of increasing railway taxation in Michigan gave Professor Adams an opportunity to experiment with his project within the limits of that State."