name extends beyond the line of that column. People v. Sierra Buttes Quartz Min. Co., 39 Cal. 371.

In New York, the value of personal property must be placed in a fourth column. People v. Hagadorn, 104 N. Y. 516.

The rate per cent. and the amount of the tax assessed are in some states placed in another column. State v. Perkins, 24 N. J. L. 409; State v. Sloss, 87 Ala. 119; Thompson v. Honey Creek Draining Co., 33 Ind. 268.

Formal Errors or omissions.-But the omission to comply with a merely formal requisite directory in its nature, does not invalidate the assessment. See Downing v. Roberts, 21 Vt. 441; Henry v. Chester, 15 Vt. 460; Stearns v. Miller, 25 Vt. 20; State v. Bishop, 34 N. J. L. 45; State v. Manning, 41 N. J. L. 275; Thomas v. Chapin, 116 Mo. 396; Torrey v. Millbury, 21 Pick.(Mass.) 64; Blackburn v. Walpole, 9 Pick. (Mass.) 97; Pacific Hotel Co. v. Leib, 83 Ill. 604; Wall v. Trumbull, 16 Mich. 228.

In People v. Clapp (Supreme Ct.), 19 N. Y. Supp. 531, it was held that the assessment roll need not be in a single volume or collection of sheets united together, if they are united when finally completed with the verification attached.

1. Jenkins v. McTigue, 22 Fed. Rep. 148. And see San Luis Obispo County v. White (Cal. 1890), 24 Pac. Rep. 864; Emeric v. Alvarado, 90 Cal. 444; State v. Allen, 43 Ill. 456; Elston v. Kennicott, 46 Ill. 187; Chickering v. Faile, 38 Ill. 342; Jackson v. Cummings, 15 Ill. 449; Bird v. Perkins, 33 Mich. 28; First Nat. Bank v. St. Joseph, 46 Mich. 526; State v. Sadler, 21 Nev. 13; Ward v. Gallatin County, 12 Mont. 23; Ensign v. Barse, 107 N. Y. 329; Chamberlain v. Taylor, 36 Hun (N. Y.) 24; Hopkins v. Young, 15 R. I. 48; Spokane Falls v. Browne, 3 Wash. 84; Sawyer v. Gleason, 59 N. H. 140.

The abbreviation "dolls." is equiva

lent to the word "dollars." Salisbury v. Shirley, 66 Cal. 223.

Where the dollar mark is placed at the head of the column, it is not necessary that it should be prefixed to each item. State v. Sadler, 21 Nev. 13.

In re Church of the Holy Sepulchre, 61 How. Pr. (N. Y.) 315, it was held that the omission of anything to indicate whether the figures represented dollars or cents, invalidated the assessment. See also Tilton v. Oregon Cent., etc., Road Co., 3 Sawyer (U. S.) 22; Emeric v. Alvarado, 90 Cal. 444.

2. Kelsey v. Abbott, 13 Cal. 609; Dowell v. Portland, 13 Oregon 248; Albany City Bank v. Maher, 19 Blatchf. (U. S.) 175; Hayes v. Viator, 33 La. Ann. 1162; Lynam v. Anderson, 9 Neb. 367; Whitney v. Thomas, 23 N. Y. 281; Evans v. Newell (R. I. 1892), 25 Atl. Rep. 347; Philadelphia v. Miller, 49 Pa. St. 440; Putnam v. Tyler, 117 Pa. St. 570; Lyman v. Philadelphia, 56 Pa. St. 488.

Where the statute requires money in court to be assessed to the treasurer, assessment to the plaintiff is invalid. San Luis Obispo v. Pettit, 87 Cal. 499.

In Crawford v. Schmidt, 47 Cal. 617, it was held that the designation of the owner by his surname alone was insufficient.

The name of the owner or occupant must appear on the assessment roll. Dubois v. Webster, 7 Hun (N. Y.) 371.

3. See Jefferson v. Mock, 74 Mo. 61; State v. Gibson, 12 Mo. App. 1; People v. Whipple, 47 Cal. 591; Lake County v. Sulphur Bank, etc., Min. Co., 66 Cal. 17; Bell v. Barnard, 37 Ill. App. 275; State v. Sloss, 87 Ala. 119; Wheeler v. Bramel (Ky. 1888), 8 S. W. Rep. 199.

In Parker v. Cochran, 64 Iowa 757, it was held that where taxes on land were duly assessed to the owner, the omission of the owner's name in transcribing the tax into a tax list does not invalidate the assessment.

4. Lynam v. Anderson, 9 Neb. 367.

And see Pease v. Whitney, 5 Mass. 380; Meyer v. Trubee, 59 Čonn. 422; Willard v. Blount, 11 Ired. (N. Car.) 624; Madison v. Whitney, 21 Ind. 261; Springfield v. First Nat. Bank, 87 Mo. 441; Henkle v. Keota, 68 Iowa 334; Bird v. Benlisa, 142 U. S. 664.

An assessment made to a person by name is to be deemed an assessment to him as owner. Blatner v. Davis, 32 Cal. 328.

1. Le Blanc v. Blodgett, 34 La. Ann. 107; Denegre v. Gerac, 35 La. Ann. 952; Maspereau v. New Orleans, 38 La. Ann. 400; Workingmen's Bank v. Lannes, 30 La. Ann. 871; Norres v. Hays, 44 La. Ann. 907; Dowell v. Portland, 13 Oregon 248; Redmund v. Banks, 60 Miss. 293; Philadelphia v. Miller, 49 Pa. St. 440; Baer v. Choir (Wash. 1893), 32 Pac. Rep. 776; Milwaukee Iron Co. v. Hubbard, 29 Wis. 51; Hecht v. Boughton, 2 Wyoming 368; Tracy v. Reed, 38 Fed. Rep. 69; Brown v. Veazie, 25 Me. 359; Bidleman v. Brooks, 28 Cal. 72; Green v. Craft, 28 Miss. 70; Lassitter v. Lee, 68 Ala. 287; Hume v. Wainscott, 46 Mo. 145; Abbott v. Lindenbower, 42 Mo. 162; State v. Gibson, 12 Mo. App. 1; Barker v. Blake, 36 Me. 433; Picotter v. Whaley, 80 Mich. 257; State v. Vanderbilt, 33 N. J. L. 38; Smith v. Read, 51 Conn. 10; Thompson v. Ela, 60 N. H. 562; Perham v. Haverhill Fibre Co., 64 N. H. 2; Burpee v. Russell, 64 N. H. 62; Crook v. Anniston City Land Co., 93 Ala. 4; Klumpke v. Baker, 68 Cal. 559; Hearst v. Egglestone, 55 Cal. 365; Newell v. Wheeler, 48 N. Y. 486; Whitney v. Thomas, 23 N. Y. 281; Zink v. McManus (Supreme Ct.), 3 N. Y. Supp. 487; Desmond v. Babbitt, 117 Mass. 233; Lynde v. Brown, 143 Mass. 337; L'Engle v. Florida Cent., etc., R. Co., 21 Fla. 353; People v. Whipple, 47 Cal. 591; Sargent v. Bean, 7 Gray (Mass.) 125. Such an assessment is equivalent to an entire omission of the name. People v. Whipple, 47 Cal. 591;

Lewis v. Withers, 44 Fed. Rep. 165; Johnson v. M'Intire, I Bibb (Ky.) 295; Wheeler v. Bramel (Ky. 1888), 8 S. W. Rep. 199; Baskins v. Doe, 24 Miss. 431. Compare Clifton Heights Land Co. v. Randell, 82 Iowa 89.

Thus, if property is assessed in the name of the agent of the owner, the interest of the owner is not covered by the lien. Meyer v. Trubee, 59 Conn. 422. And where land is not assessed to the owner, and is knocked down to the state at a tax sale, the state takes nothing. McWilliams v. Michel, 43 La. Ann. 984.

A statute limiting the right of the former owner to redeem to one year, has no application where the land is not assessed to the owner. Bird v. Benlisa, 142 U. S. 664. And see Davenport v. Knox, 34 La. Ann. 407; Person v. O'Neal, 32 La. Ann. 228.

2. Robinson v. Williams (La. 1893), 12 So. Rep. 499. And see Bird v. Benlisa, 142 Ü. S. 664; Tracy v. Reed, 38 Fed. Rep. 69.

3. Barker v. Hesseltine, 27 Me. 354. And see Oliver v. Robinson, 58 Ala. 46; Klumpke v. Baker, 68 Cal. 559; Meyer v. Trubee, 59 Conn. 422; Nichols v. McGlathery, 43 Iowa 189; Sutton v. Calhoun, 14 La. Ann. 205; Rapp v. Lowrey, 30 La. Ann. 1272; Perham v. Haverhill Fibre Co., 64 N. H. 2. But see Corning Town Co. v. Davis, 44 Iowa 622; State v. Hurt, 113 Mo. 90.

The knowledge of one assessor as to ownership will be imputed to all. Thompson v. Gerrish, 57 N. H. 85.

An assessor can demand of a warehouseman the ownership of property in his possession. Bode v. Holtz, 65 Cal. 106.

4. See Stilz v. Indianapolis, 81 Ind. 582; Schrodt v. Deputy, 88 Ind. 90; Small v. Lawrenceburgh, 28 Ind. 231; Merrick v. Hutt, 15 Ark. 331; Garibaldi v. Jenkins, 27 Ark. 453; Kinsworthy v. Mitchell, 21 Ark. 145; Landregan v. Peppin, 86 Cal. 122; Peo

ple v. Home Ins. Co., 29 Cal. 533; Union Trust Co. v. Weber, 96 Ill. 346; Haight v. New York, 99 N. Y. 280; Collins v. Long Island City, 56 Hun (N. Y.) 647; People v. Barker, 67 Hun (N. Y.) 649; State v. Matthews, 40 N. J. L. 269; State v. Vanderbilt, 33 N. J. L. 38; Lynam v. Anderson, 9 Neb. 367; Bradley v. Bouchard, 85 Mich. 18; Petrie Lumber Co. v. Collins, 66 Mich. 64; Michigan Dairy Co. v. McKinlay, 70 Mich. 574; Hill v. Graham, 72 Mich. 659; Strauch v. Shoemaker, 1.W. & S. (Pa.) 166; Glass v. Gilbert, 58 Pa. St. 266; Dunn v. Winston, 31 Miss. 135.

Under the Indiana statute, the fact that a wife's land was charged in the name of the husband, does not invalidate the assessment. Helms v. Wagner, 102 Ind. 385.

In Tyler v. Hardwick, 6 Met. (Mass.) 470, it was held that the statute applied to a person whose surname only was inserted in the assessment, and that, provided the party was taxable and could be identified by the assessors, no error in the name would invalidate the tax. See also Westhampton v. Searle, 127 Mass. 502.

In Collins v. Long Island City, 56 Hun (N. Y.) 647, it was held that under such a statute, an assessment of land of non-residents was not vitiated by being assessed to unknown owners.

1. Pearson v. Creed, 78 Cal. 144; Greenwood v. Adams, So Cal. 74; Jatum v. O'Brien, 89 Cal. 57; Daly v. Ah Goon, 64 Cal. 512; Grinn v. O'Connell, 54 Cal. 522; Hearst v. Egglestone, 55 Cal. 365; Grotefend v. Ultz, 53 Cal. 666; Stafford v. Twitchell, 33 La. Ann. 520. And see Bosworth v. Webster, 64 Cal. 1; Brunn v. Murphy, 29 Cal. 326.

In California, an assessment to the owner and all claimants is invalid. Daly v. Ah Goon, 64 Cal. 512; Brady v. Dowden, 59 Cal. 51; Pierson v. Creed, 78 Cal. 144; Hearst v. Egglestone, 55 Cal. 365.

But where the land is assessed to the owner, the general heading of the assessment roll "to all owners, claimants, known or unknown, etc.," will not vitiate it. Bosworth v. Webster, 64 Cal. I; San Francisco v. Phelan, 61 Cal. 617. 2. Dubois v. Webster, 7 Hun (N. Y.) 371; Grotefend v. Ultz, 53 Cal. 666; Sargent v. Bean, 7 Gray (Mass.) 125. And see People v. Wemple, 53 Hun (N. Y.) 197.

But in whosesoever name the assessment is, the succeeding steps must be in the same name; viz., in the advertisement and sale. Bettirson Budd, 21 Ark. 578. See also Shimmin v. Inman, 26 Me. 232; Watt v. Gilgore, 2 Yeates (Pa.) 330.

V.

3. Cardigan v. Page, 6 N. H. 182; Smith v. Messer, 17 N. H. 420; Merritt v. Thompson, 13 Ill. 716; Corning Town Co. v. Davis, 44 Iowa 622; Brown v. Veazie, 25 Me. 359; Jenkins v. McTigue, 22 Fed. Rep. 148; Jackson v. Cummings, 15 Ill. 449; Burdick v. Connell, 69 Iowa 458; Griffin v. Tuttle, 74 Iowa 219.

The fact that the owner was known to the purchaser at the tax sale is immaterial. Lassitter v. Lee, 68 Ala. 287.

In California, it is necessary, where lands are assessed to unknown owners, that the assessor should state in his list that it was so assessed because it was unoccupied and the owner unknown. Moss v. Shear, 25 Cal. 38; 85 Am. Dec. 94; Smith v. Davis, 30 Cal. 536. But compare Brunn v. Murphy, 29 Cal. 326.

4. Trowbridge v. Horan, 78 N. Y. 439; Hardy v. Yarmouth, 6 Allen (Mass.) 277; Latrobe v. Baltimore, 19 Md. 13; People v. Coleman, 53 Hun (N. Y.) 482.

5. See Welles v. Battelle, 11 Mass. 477; Lake County v. Sulphur Bank, etc., Min. Co., 68 Cal. 14; Meyer v. Trubee, 59 Conn. 422; People v. Coleman, 53 Hun (N. Y.) 482.

Under the Illinois statute, the word "agent need not be added when the

agent has neglected to list the property. Lockwood v. Johnson, 106 Ill. 334.

In Lake County v. Silver Bank, etc., Min. Co., 68 Cal. 14, it was held that an assessment to the company, "F. Fiedler, agent," indicated an assessment to the company.

1. See Williams v. Holden. 4 Wend. (N. Y.) 223; McLean v. Horn (Supreme Ct.), 17 N. Y. Supp. 119; San Francisco v. Pennie, 93 Cal. 465; State v. Holmdel Tp., 39 N. J. L. 79; Wolfe v. Geffroy, 16 Ohio St. 219.

Where the assessment is imposed upon administrators, it is an assessment upon the administrators themselves, and will support a commitment under the New York statute for failure to pay the tax. McLean v. Horn (Supreme Ct.), 17 N. Y. Supp. 119.

But in State v. Runyon, 41 N. J. L. 98, it was held that an assessment against one of several executors should not be set aside, though the assessor failed to designate his representative capacity.

In Bath v. Reed, 78 Me. 276, it was held that an assessment against parties as "administrators," when it should have been against them as executors, did not invalidate the tax.

Where the administrator has distributed the estate among the parties entitled thereto, no tax can be assessed against him. Carleton v. Ashburnham, 102 Mass. 348.

2. Hubbard v. Winsor, 15 Mich. 146; Hill v. Graham, 72 Mich. 659; Van Dyke v. Carleton, 61 N. H. 574; People v. Ferguson, 8 Cow. (N. Y.) 102; Wheeler v. Anthony, 10 Wend. (N. Y.) 346. And see Petrie Lumber Co. v. Collins, 66 Mich. 64.

It should be assessed in the firm name, even though the title to the property has vested in the survivors, owing to the death of one of the partners. Blodgett v. Muskegon, 60 Mich. 580.

An assessment of the personal property of a former member of a firm after

dissolution of the firm, is void. People v. Sneath, 28 Cal. 612.

3. Cooley on Taxation (2d ed.) 399, citing Hayes v. Viator, 33 La. Ann. 1162. And see Payne v. Danley, 18 Ark. 441; 68 Am. Dec. 187; Jenkins v. Rice, 84 Ind. 342; Noble v. Indianapolis, 16 Ind. 506; Norres v. Hays, 44 La. Ann. 907.

In State v. Rand, 39 Minn. 502, it was held that a credit consisting of part of the purchase price of land formerly owned in common, should not be assessed as a whole against the vendors.

An assessment cannot be invalidated by the fact that one of several cotenants has been named as owner. Fleischauer v. West Hoboken, 40 N. J. L. 109; Welles v. Battelle, 1 Mass. 477. And see Factors', etc., Ins. Co. v. Levi, 42 La. Ann. 432; Williams v. Holden, 4 Wend. (N. Y.) 223; Howard v. Proctor, 7 Gray (Mass.) 128.

4. Pierce v. Richardson, 37 N. H. 306; Carpenter v. Dalton, 58 Ñ. H. 615; Souhegan Nail, etc., Factory v. McConihe, 7 N. H. 309; Van Dyke v. Carleton, 6 N. H. 574; Tyler v. Hardwick, 6 Met. (Mass.) 470; Farnsworth Co. v. Rand, 65 Me. 19; Hill v. Graham, 72 Mich. 659; O'Neal v. Virginia, etc., Bridge Co., 18 Md. 1; Van Voorhis v. Budd, 39 Barb. (N. Y.) 479; In re Hartshorn, 63 Hun (N. Y.) 623; McLean v. Horn (Supreme Ct.), 17 N. Y. Supp. 119; State v. Diamond Valley Live Stock, etc., Co., 21 Nev. 86; People v. Sierra Buttes Quartz Min. Co., 39 Cal. 511; Lyle v. Jacques, 101 Ill. 644; People v. Tax Com'rs (Supreme Ct.), 17 N. Y. Supp. 923; Pennington v. Mendes, 38 N. J. Eq. 336; State v. Matthews, 40 N. J. L. 269. And see Westhampton v. Searle, 127 Mass. 502.

In Adams v. Sleeper, 64 Vt. 544, it was held that a tax levied on the property of a wife is not illegal because assessed in the name of both husband and wife, such error being harmless.