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sentences as the following, extracted from the 23rd report:"The fluctuations in value are due to corrections in the assessment for the previous year. Moreover, it may be observed that, as land becomes built upon and appropriated to other uses, the value ceases to be classed under the heading 'lands,' and becomes chargeable as for houses' under Schedule A or profits under Schedule D." The Commissioners of Inland Revenue have never asserted that the returns for "Lands, &c.," represented the agricultural rental with any precision. Thus, in their report of 1883 (p. 41) they say: "The decline in the valuation of lands above shown of £480,941 exhibits to a greater extent than any preceding year the depreciation in value of landed property, so far as the same can be judged by income-tax statistics solely." Indeed, a study of the series of reports shows most clearly that the factors which go to make the figures are in a constant state of flux, and that the territorial extent of "Lands. &c.," varies from year to year so greatly that it is quite impossible to trace the agricultural rental from the returns for "lands." Further, the report of 1892, in reference to the gross disproportion between local valuation and income-tax assessments (a disproportion amounting to more than 40 per cent. in the extreme cases of Anglesey and Carnarvonshire), points out that many occupiers made false returns to the income-tax, not so much because they feared the income-tax as because they feared their rateable value might be increased, from which it follows that income-tax statistics, even if they purported to represent the farming rental, which they do not, would be untrustworthy, and particularly untrustworthy in the case of the counties named. Figures, in fact, must not be trusted for more than they are worth.

These are some of the general reasons for believing that the returns for "lands" must be subject to large and varying deductions of unknown quantity before the agricultural rental

can be ascertained. In truth, the returns for "lands" can only approach to a representation of the agricultural rental when we study the returns for survey districts in isolated agricultural localities. Towns upset the whole calculation. This I am able to do for the years 1876-77 to 1885-86, after which the survey districts, or some of them, were rearranged, so that comparison becomes difficult. I give the figures obtained from the Inland Revenue in relation to the county - of Essex :

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These are figures of a very striking character, showing that, while the annual value of lands in the county fell by £386,537, the annual value of lands in that portion of the county of Essex which is included in the Cambridge survey district actually rose by all but £20,000. True, there may have been special local causes at Cambridge, but special local causes, which are numerous, go to make our point, which is that many varying factors go to make the aggregate figures. Special reasons why the returns for Wales under "Lands, &c.," do not represent the agricultural rental are:

(1) That the holdings in Wales being notoriously smaller than those in England, the expenditure by owners on structural repairs is necessarily greater in Wales than in England.

(2) That the permanent depression in England has been met by permanent reductions, which diminish the return for

lands, while the return for Wales makes no account of the almost universal temporary abatements, which are far greater in proportion than in England.

(3) That the very large number of some-time tenants, especially in Carnarvon and Anglesey, who have bought their holdings, being exempt from income-tax, are indifferent to the figure at which their little properties stand in the income-tax books. Moreover, many of these purchases have been made under circumstances where it is not unreasonable to believe that the purchase-money was borrowed at a higher rate of interest than the land was likely to repay in the form of rent under existing agricultural conditions, and in those cases the assessors have very properly raised the assessment. For example, when a man has paid £1000 borrowed at 4 per cent. for property rented at £30 or less, the assessment has been raised to £40; and it is beyond dispute that in parts of North Wales the land has been assessed in this manner at a fictitious value, and the assessment cannot consequently serve as a sure guide to the agricultural value.

Finally, Mr. Gladstone, writing to Lord Sudeley, invited a comparison upon the basis of the returns for lands between Wales and England more or less like Wales. I have the materials for such a comparison, and invite Mr. Gladstone's attention to the following figures:

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So that Wales fell in almost identical proportion with our English counties of a similar annual value at the outset. I do not, however, think that either of these falls represent the fall of agricultural rental, and I am inclined to think, when I remember my illustrations from Essex, that the agricultural rental has declined far more seriously, while the value of "lands" has been kept up, especially in Carnarvonshire and Anglesey, by the steady growth of small residential holdings round such places as Llandudno, Bangor, Carnarvon, Pwllheli, Criccieth, Menai Bridge, Beaumaris and Llangefni. In conclusion I venture to assert that to ascertain with any approach to accuracy the purely agricultural rental of North Wales, or of a single county in it, for a single year by the help of any existing statistics is a matter of impossibility. In the meantime, it is evident that, in taking figures which cannot be relied on for the basis of his accusations, Mr. Gladstone has shown injustice towards the landowners of Wales whom he has assailed.

Yours, &c.,

GEO. H. M. OWEN,

Secretary North Wales Property Defence Association.

Carnarvon, Jan. 3.

APPENDIX II.

The following are the figures and statements as to abatements, reductions and history of rental, obtained by the late Mr. George Owen, under the hands of the landowners and agents making the returns. None have been omitted :

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