In the rates of capitalization and annuity used in 1902, there were certain changes, making them differ from those used in 1900, and certain changes in the detail of analysis of income accounts and methods of determining the rates of interest which are entirely immaterial to the present narrative. The work was of great importance as being the first exposition of this method of obtaining non-physical values. It was a fair, logical, and business-like attempt to determine those elements which give a well-designed, economically-built, or advantageously-located property a greater value as a money-earning concern than the actual capital invested, or than the actual value remaining in its physical property. It will be seen that, in the case of a property in which the surplus earnings depend on excessive rates for service, it will fail as a method of determining a value for use as a basis of rate-making; and it fails, in the form in which it was used in 1900 and 1902, to bring out those negative or subtractive elements which may be determined from the income accounts, in the case of properties which do not earn a fair return on the investment. This, however, was due to the fact that the taxation laws of Michigan made no provision for any reduction of value because property was idle or non-productive, and any such deduction in the case of corporation property would place it on a different basis from other property. Professor Adams and his associates, therefore, applied only positive values, where any such were found, although advocating the use of negative values. The writer has seen no criticism of Professor Adams' work which is not apparently incited by, either the direct interest of corporations in lowering valuations for taxation, or by an effort to confuse the subject of valuation so as to discredit the work in the eyes of taxing authorities. Any person competent to discuss the matter, who has given Professor Adams' method careful thought, will be forced to the conclusion that this was a long step in the direction of the final solution of these important and perplexing elements of value. History and Results of the Michigan Appraisal. Based on the valuation of 1900, the Board of State Tax Commissioners was enabled to comply with the statute in reporting to the Legislature. New laws were passed, sundry suits were brought, and, finally, the case of the Michigan Central Railroad _vs._ Perry F. Powers, Auditor-General, and a number of other cases in behalf of other roads, were brought to trial before the United States Court for the Western District of Michigan.