The question of the fair return on money invested is not referred to, for the reason that it has no direct bearing on valuation, and for the further reason that it has been quite exhaustively discussed in the papers listed in the Appendix. The writer desires to make clear the fact that he is not advocating low rates _per se_. The rate must be determined to meet the special requirements of each investigation. The Supreme Court of Maine says (97 Maine): "The reasonableness of the rate may for a time be affected by the degree of hazard to which the original enterprise was naturally subjected. That is such hazard only as may have been justly contemplated by those who made the original investment, and not unforeseen and emergent risks, and such allowances may be made as is demanded by ample and fair public policy." While the Supreme Court of the United States, in Willcox _vs._ Consolidated Gas (212 U. S., 12), fixed a rate of 5½% as reasonable in that instance, they said: "No particular rate of compensation must in all cases be regarded as sufficient for capital invested in business enterprises. Such compensation must depend greatly on circumstances and locality. Among other things the amount of risk in the business is an important factor, as well as the locality where the business is conducted and the rate expected and usually realized there upon investments of a somewhat similar nature with regard to the risk attending them. There may be other matters which in some cases might also be properly taken into account in determining the rate which an investor might properly expect or hope to receive and which he would be entitled to without legislative interference. The less risk, the less right to any unusual return upon the investments." In view of these dicta, it is needless to argue whether a rate of 6% or 10%, or 15%, or more, be reasonable. The writer has herein endeavored to narrate the story of the Michigan appraisal in some detail, to review briefly subsequent similar work, to present the main points in the legal decisions bearing on appraisal practice, and to present his own views as to proper and legitimate methods of valuation in the light of judicial opinions. He has attempted to do this in the spirit of absolute fairness, without permitting either early years of training in corporation service, or more recent investigations for State and city, to bias the presentation of truths.