Samuel Freeman Miller

“ It is certainly a much more equitable mode of determining how much of his property for the year preceding the assessment is liable to taxation, and how much is exempt, and more nearly effects the purpose of the federal statute, as well as that of the state of Ohio, to exempt the one and to tax the other, than a rule which assumes that the condition of the means and property of the tax-payer at a certain hour of a particular day in the year shall constitute the basis of his taxation for the entire year. ”

“ We know of no principle which forbids that state from taking the whole period of a business year already past as the best means of ascertaining how much the taxpayers shall be required to pay on property which is admitted to be taxable, and how much he shall deduct for the non-taxable securities of the state and of the United States. ”

“ Therefore, in Ohio, United States securities are only exempted from taxation in a limited manner; that is, in proportion to the time they have been held. All other property is treated differently. If anything is unconstitutional, it seems to me that this is. ”