The Valuation of Public Service Corporation Property: Transactions of the American Society of Civil Engineers,; vol. LXXII, June, 1911, ASCE 1190Riggs, Henry Earle
General
The Valuation of Public Service Corporation Property: Transactions of the American Society of Civil Engineers,; vol. LXXII, June, 1911, ASCE 1190
"The true value of a line of railroad is something more than an
aggregation of the values of the separate parts of it, operated
separately. It is the aggregate of those values plus that arising
from a connected operation of the whole, and each part of the road
contributes not merely the value arising from its independent
operation, but its mileage proportion of that flowing from a
continuous and connected operation of the whole.... The value of
property results from the use to which it is put, and varies with
the profitableness of that use, past, present and prospective,
actual and anticipated. There is no pecuniary value outside that
which results from such use....
"In the nature of things it is practically impossible, at least in
respect to railroad property, to divide its value and determine how
much is caused by one use to which it is put and how much by
another. Take the case before us, it is impossible to disintegrate
the value of that portion of the road within the State of Indiana
and determine how much of that value springs from its use in doing
interstate business and how much from its use in doing business
wholly within the State. An attempt to do so would be entering upon
a mere field of uncertainty and speculation."
In the Michigan cases, the principal one being Michigan Central Railroad
_vs._ Powers (201 U. S., 245), the question of method of valuation was
not passed on by the Courts for the reason that, after the evidence was
in, and during the argument, counsel for the railroad admitted that the
Cooley valuation was as correct a figure as it was possible to secure
under then existing conditions, methods and rates of taxation being the
issue.
It is thus seen that the Supreme Court of the United States was not, in
any of the earlier cases, required to pass squarely on the propriety of
any method of arriving at a "fair value," and consequently had not,
prior to 1909, defined any hard-and-fast rules of procedure in
determining such value. The Circuit Courts have passed on kindred
questions in a few cases, among which San Diego Land and Town Company
_vs._ National City (74 Fed., 83), and San Diego Land and Town Company
_vs._ Jasper (110 Fed., 714) hold as above, and cite most of the cases
referred to. In the latter case the Court says:
"The actual value of such property obviously depends upon a variety
of considerations—among them the actual and prospective number of
consumers—and is no more unchangeable than the value of any other
kind of property."
As an illustration, there is cited the effect of a year's drouth on an
irrigation plant as temporarily affecting the value of property.
In the case of Cotting _vs._ Kansas City Stock Yards (82 Fed., 839) the
Circuit Court touches on one very interesting argument, in the light of
some of the methods of valuation advocated by railway managers and some
of the criticisms of recent valuation work.
Public-domain text, read in full here on John Shaqi.
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