Semi-weekly standard. [volume] (Raleigh, N.C.) 1853-18??, 1863-04-28
RALEIGH, April II, 1868.

Jonathan Worth, Esq, Public Treasurer:
DEAR SIR:-l answered the first question pro-
pounded in yours of the lst instant, before left
Raleigh for the eastern portion of the State, from
which place have just returned.
la reply to your second question, am of opinion
that the real estate should be listed by the corpora
:ion or company or individual, the case may be;
and in estimating the value, all improvements, in
cluding machinery, fixtures, &c, that have teen
erected or used thereon should be embraced The
term improvements" in the Sth section, were 1t
not for the 9Th section, would not be- by me, made
SO comprehensive BY this latter section, in eSti-
mating the value of every tract OF land, or other
real estate with the improvements thereon the ma
chInery, fixtures, &c, 70 be taken into the
estimate.
By paragraph f. section and section g. it ap-
pears that where there is Stock 1t is to De given in
by the individual owner in the district in which
he resides, and where there is no corporation or
stock issued the "intcrest," whatever 1t may be
in the business" must be given in by the owner
in addition to the value of the real estate de-
scriDed in sections and g.
Whatever the intention may have been the Leg
islature could my opinion have used no stronger
language to convey the idea that they intended 10
tax the same property twice first as stock or money
invested, and then as real estate
As to your thru question, | am Of opinion, that
in a aliition to the tax to be levied upon the real
estate as aScertained by sections and g. and upon
the "StOck interest" in any "cJrpOratiOn or
business" as ascertained by section /, paragraph
4, and section 8, section 7': paragraph 10, i'm
poses an additional tax "Ou every dollar of net
profit or dividend, declared, received or due ring
the year preceding the FIST of April in each year
upon money or capt- invested in manufacturing
cotton wooden gocds leather, articles made of
cotton, iron and tobacco, and also on every dollar
Of net profit or dividend, or money Invested in
steamboat Companies"
Therefore, | conclude that the Legislature in
tended to tax, lst the corpus, which is the property
material substance of the corpOration and exists
whether proftably employed or uot and this is a
tax upon the corporation; 2jE the shares Of each
owner, if more than one, or money invested, il
there be no shares, which is q tax upon the indi-
vidual members and Sd, che profits or dividends
which is a distinct thing rom either Of the former
which may be considered a tax upon the corpora
upon the Interest" and the "business, terms
used in the bill in connection with shares and cor
pOratiOns.
/ ain Of oSinion that the term manufacturing in
your 4th question, should be taken in its largest
sense as 70 embrace mills Tor the manufacture Of
flour, iron, paper &c,
FurthCr, am of opinion that paragraph Is, Sec
ton 20, of the Revenue act, does not conflict with
tie chartered rights of the Wilmington and Wei.
dJn Railroad and that the tax thereby imposed
ought to be paid.
desire to call the attention of sheriffs to 69th
section of the Revenue act
/ am, with great respect
SION II. ROGERS,
4Atty Gen'l n. c.