The statement is made again and again that the Michigan work was a physical valuation; that no attempt was made to secure a "fair value" (the language of the Courts), and that the value as a going concern was not attempted to be given. In no case is the statement made that Professor Cooley had charge of the physical valuation in Michigan, and that Professor Adams took this physical valuation, and, under his method, treated it as one element, and with it and other data derived from a study of the reports and earnings of the company, undertook to determine a "non-physical," "intangible," "franchise," or "going concern" value, which included all tangible elements, and which, added to the physical value, was assumed by Professor Adams to give the true value. Had such a statement been fairly made, no possible objection could be raised to the making of any number of points against the correctness of the methods used by Professor Adams. "Certainly it cannot be denied that a road between New York and Chicago, 950 miles in length, passing through a manufacturing district, is of greater value than a road 1,200 miles in length, between the same cities, but passing through a hilly and undeveloped territory a portion of the distance, and through a farming section for a greater portion of the remaining distance; yet the advocates of a physical valuation would have us believe that there is no difference in the value of the two if they can be reproduced to-day at the same cost." This statement is entirely unfair to every man who has been in responsible charge of valuation work in recent years in the United States. No theory has ever been favored by any honest-thinking advocate of a valuation. In the first place, no interstate valuations have ever been made, and no parallel case to the one assumed is to be found, except for very short sections of roads, a very marked instance having been referred to elsewhere in this paper. Such a condition as assumed would be reflected in the earnings of the companies to such an extent as to cause the non-physical element of Professor Adams as used in Michigan to correct largely or wholly the inequality and inaccuracy of the physical valuation; such at least was the theory, and, if carried to its logical end by the use of negative non-physical values, such would be the result.