A A cz :n 1 1 9 4 Calif C3rnia State Tax Association The Problem of Taxation in California THE LIBRARY OF THE UNIVERSITY OF CALIFORNIA LOS ANGELES EX LIBRIS EDWARD A. DICKSON I 879-1 956 REGENT OF THE UNIVERSITY I913-I956 CALIFORNIA STATE TAX ASSOCIATION. THE PROBLEM OF TAXATION IN CALIFORNIA Being a Brief Discussion of the Revenue System, State and Local, the Administration of Revenue Laws, and Measures Pending Before the Legislature Looking to the Improvement of the System and Its Administration. February 20, 191 5. CALIFORNIA STATE TAX ASSOCIATION. CALIFORNIA STATE TAX ASSOCIATION. THE PROBLEM OF TAXATION IN CALIFORNIA Containing Page Introduction * Discussion of present revenue system 3 Administration of local revenue laws 9 Summary of pending measures 15 SAN FRANCISCO: The Recorder Printing and PublislJing Company 1915 INTRODUCTION. The present condition of State revenues, combined with the tremendous increases in local taxation during the past four years and the difficulties experienced by the State in its efforts to equalize corporation taxes, has brought the Legislature to con- sider the advisability of inaugurating a general program of State and local tax reform in California. In three pending measures the first steps towards revising the revenue system and improving the administrative machinery are proposed. Although these measures supply only the ground- work for the changes which it will be necessary to make two years hence, they are none the less important or deserving of attention from every member of the Legislature and every tax- payer. It is to facilitate an understanding of these measures, of the conditions which gave rise to their introduction, and of what is expected to be accomplished under them, that this statement has been prepared. No apology is made for the subject; taxation is not a popular theme, although it touches directly a greater proportion of the people than any other function of government. Public under- standing of its elements and its problems is neglected only at the peril of the public. A careful reading of this pamphlet is urged upon every legislator, administrative official and citizen. The discussion falls naturally into three parts: First, as to the present tax system; second, as to the administration of local revenue laws; and third, as to the pending measures. The whole is intended to be briefly comprehensive rather than discursive, and to present a summary of the arguments in behalf of the pending legislation at Sacramento. DUDLEY GATES, Secretary. CALIFORNIA STATE TAX ASSOCIATION. H 1. AS TO THE TAX SYSTEM. California in 1910 adopted a tax system providing for the sep- aration of state and local revenues, certain properties being selected for exclusive taxation by the state. After four full years' experience, a general survey of the sys- tem leads to these conclusions: First, the revenues accruing to the state do not increase pro- portionately with the state's needs, and in other essentials the system fails to meet the promises made for it; Second, serious problems and defects not anticipated in 1910 have developed in its administration; Third, revision is necessary before these shortcomings and de- fects, which are cumulative, work injury to the state; Fourth, a return to the principles and methods discarded in in 1910 is impossible; Fifth, a thorough investigation must be made before the open- ing of the next legislature in 1917; and Sixth, in order to obtain immediate results from such an in- vestigation, the next legislature must be given power to revise the system. A. Revenues Fall Behind State's Needs. At the time the Constitutional Amendment embodying the present plan of taxation was before the people in 1910, the pro- ponents of the measure claimed, among many others, the follow- ing advantages for the new system: (i) The corporations thereafter would pay all of the State's expenses; (2) The difficulties of equalization would be ended; (3) The conditions of local taxation would improve; and (4) The tax burden on local real estate would be materially lightened. State Revenues Inadequate. In promising (i) that the corporations would pay all of the State's expenses, it evidently was assumed that the State's needs would increase at a fixed rate, that no State revenues would be lost, and that general economic conditions aflfecting corpora- tions would remain constant as of the year 1910. Experience has disproved each of these assumptions. First, is has been found that the needs of the State increase faster than the inelastic revenues selected for its use. Second, two sources of revenue counted on to help sustain the separation plan ( i. c., the poll tax and corporation license tax) have been lost. Third, economic conditions have not remained constant as of the year 1910 but have changed to such an extent as to aflfect seriously the gross earnings of the public utility corporations taxed for State purposes. 905564 The combined effect of these three factors has been to create a prospective deficit in the coming biennial period of approxi- mately $1,500,000, which the Legislature must meet either through the levy of a State ad valorem tax or by experimenting in the field of "new revenue sources." Equalization Problems Unsolved. In promising (2) that adoption of the present tax system would bring an end to the difficulties of equalization, it was as- sumed that the rates originally applied to the gross earnings of corporations established these properties on an equality with property at large for years to come, and that these rates would bear with substantial equality upon the individual corporations within each group. As against these assumptions, it must be set down: First, that a new equalization between corporations and general prop- erty has been necessary at each session of the Legislature, in 1913 and in 191 5; and second, that the gross earnings rates ap- plied to the corporations do not bear evenly upon the individual corporations within the several groups, but in their effect vary widely from the average. Local Conditions Unchanged. In promising (3) that separation would improve the conditions of local taxation, it was assumed that the undervaluation of prop- erty was caused solely by the desire of county assessors to evade part of the State tax, and that without a State levy undervalua- tion would cease. It is a matter of common knowledge that undervaluation is practiced by local assessors exactly as in the past. Effect of Separation on Local Rates. The effect of separation on local tax rates was predicted as follows by the Special Commission on Revenue and Taxation which drafted the present laws (1906 Report, page 88): "As the overtaxation of real estate is far and away the verv worst evil in our present system, the commission feels particularly gratified that it has been able to devise a plan which will afford this class of taxpayers substantial relief." Data has not been gathered from all of the counties, but the experience of San Francisco may be taken as typical. The record of State and local tax rates in the years immediately before and after 1910 is as follows: 1908-09 State and local combined $1.90 iQOQ-io State and local combined 1.96 1910-1 1 State and local combined 2.00 *I9II-I2 Local rate only 2.00 1912-13 Local rate only 2.0.S 1913-14 Local rate only 2.20 1914-15 Local rate only 2.25 (*Separation plan in effect 1911.) The basis of valuation, approximately 50 per cent according to the assessor, has remained unchanged. The table shows, there- fore, that San Francisco, as a local taxing district, absorbed the savings promised to the taxpayer by the Revenue and Taxation Commission. Practically every local taxing district in the State has followed the same practice, with the result that the burden on real estate is as great or greater than before separation went into effect. B. Unexpected Problems and Defects. Administration of the revenue system adopted in 1910 has developed the presence of grave faults which apparently were not anticipated. A full enumeration is not attempted here, but the list includes: (i) The problem of equalization between corporations and general property; (2) The unequal burden imposed upon corporations within the same group; (3) The tendency to local extravagance; (4) The indifference of the public to the State's expendi- tures; and (5) The disadvantageous position of the State with respect to "bond refunds." The Problem of Equalization. When, as in California, certain properties (the utilities) are taxed by one method and other properties (the common forms) are taxed by a different method, it is necessary to have some basis of equalizing the burden between them; in other words, some means of expressing both taxes in terms of a rate on unit value. In order to effect this equalization, it is necessary to know (a), the basic ratio of taxes to true value in the State at large; and (b) the ad valorem rate paid by corporations taxed on their gross earnings. Determination of the first fact (a) is impeded by variations in local methods of assessment, due to lack of a uniform inter- pretation and administration of the law, and by the common practice of local assessors of undervaluation, which results in the return of property on the assessment rolls at from 25 to 50 per cent of its true value. Determination of the second fact (b) is impeded by certain inherent difficulties in the process of translating gross earnings taxes into a rate on unit value. California's equalization problem finds no parallel in any State, with the single exception of Minnesota, and there it is only one-half as difficult, by reason of the fact that through the central control of assessments, Minnesota is able to determine with a fair degree of accuracy the basic rate for the State at large. In California the very measuring-stick applied to the cor- porations is itself defective, in that its length cannot be deter- 6 mined definitely. Both in 1913 and again in 1915 corporation rates were adjusted on the vague basis of assumption and com- promise. Before 1917 a definite means of equalizing corporation taxes must be worked out and made available to the Legislature. Mys- tery in a tax system soon becomes suspicion, and justice both to the corporations and to the common taxpayer demands that it be eliminated. Corporations Unevenly Taxed. Another fruitful field of inequality is found in the attempt to apply a single rate, based on the average valuation, to all of the corporations of a particular class, such as to all railways, in- cluding street railways, all telephone companies, all gas and electric companies, etc. Even between companies of approxi- mately the same size there are wide variations, while in many cases the system gives rise to bitter complaint on the part of small companies that are plainly over-taxed. Tendency to Local Extravagance. Local tax levies all over the State have grown enormously since separation went into effect, due in part to external causes not related to the change, but partly also to the opportunity which the new plan of taxation gave local authorities to increase their levies without raising the rates. The "benefits" thus con- ferred by separation are questionable, in spite of the elaborate and attractive calculations of "net gains" that have been pub- lished from time to time. Indifference to State Expenditures. Separation makes inevitably for a careless attitude on the part of the common taxpayer towards the State's expenditures, in which he is not directly and personally interested. Without going into the merits of the several bonding measures that were before the people in the late election, it is a significant fact that one of the principal arguments for their adoption catered de- liberately to this indifference, in that voters were told that their approval would "cost nothing because the corporations pay all of the State taxes." Problem of "Bond Refunds." When the State withdrew the "operative property" of corpor- ations from local taxation, provision was made to reimburse the counties, cities and districts which had bonded themselves on the basis of their total assessment rolls prior to 1910, but no definite amount to be returned to the local districts was fixed. As a result, local assessors have taken advantage of the decen- tralized condition of the revenue system to raise the basis of as- sessment of operative property in order to increase the amounts collected from the State. The refimds, which in justice to the State should have remained stationary, increased from $650,000 in 191 1 to $742,000 in 1913 and are still growing. C. Present Tax System Must be Revised. In view of the foregoing, it is apparent that the defects of the present revenue system must be corrected before the State's revenues are more seriously embarrassed and before the other problems become too menacing. The defects that have been recited are of a general nature. There are still others that demand attention. One that has caused wide discussion relates to the methods applied in the taxation of general corporation franchises. This is California's application of the "corporate excess" tax, and under it "there is lost all of that certaintj' and simplicity and much of that relative justice w^hich are the fundamental requisites of a workable tax."* Revision means that the whole problem of taxation. State and local, must be investigated and the system overhauled and dissected. Other States have solved many of the difficulties that confront California, and it may become desirable and expedient to follow them. The point made here is that in undertaking the reconstruction of the revenue laws, not patch-work but homo- geneity must be the aim. D. Return to the Old System Impossible. One important fact should be borne in mind, namely, that the present system is a tremendous improvement over the old. Cali- fornia took a long step in advance in 1910 and with that step overcame forever many of the defects and weaknesses inherent in the old general property tax as applied to corporations. There can be no possible return to a system wrhich permits the assessment of corporate property by a hundred or more local assessors, the gerrymandering of "shoe-string" taxing districts, and the almost total escape of "intangible" values, including na- tional bank stock, franchises, etc. Furthermore, there is the principle of separation which in its application to California cannot be challenged. It is axiomatic that those properties which have not a strictly local situs de- termining their value should be taxed by the State and the pro- ceeds spent in such a way as to distribute the benefits through- out the whole State. Such properties are the railroads and other public utilities operating in two or more counties, the banks, insurance companies and corporate franchises. It will not be necessary to discard this principle in the aband- onment of complete separation. Other States that have found complete separation a failure (for California's experience follows the universal rule) have retained the principle and embodied it in some sound plan of partial separation that overcomes the vital defect of complete separation — inelasticity. Whatever changes grow out of the present situation in the *The opinion of a leading authority with respect to Cali- fornia s method of taxing franchises, quoted from Dr. Thomas S. Adams, member of the Wisconsin Tax Commission. next two years, the advantages of the system adopted in 191U must and can be saved. E. An Investigation Necessary. Revision of the tax system is of such tremendous importance that it may not be entered upon without full preparation. For that reason a complete and thorough investigation should be made before the opening of the legislative session of 1917. It is estimated that more than a year will be required to make a proper study of the tax systems of this and other States, and sat- isfactory results will not be obtained if the work is left to legis- lative committees working while the Legislature is in session. F. Prompt Action Required. To avoid delays in carrying into efTect the recommendations that will grow out of the investigation, the next Legislature must be given authority to revise that section of the Constitution which embraces the present revenue system of the State (Article XIII, Section 14). The only way to confer this power upon the Legislature of 1917 is by submitting to the people at the next general election an amendment to the Constitution and securing its ratification. Otherwise it will be necessary to wait four full years before the defective system can be changed. 2. AS TO THE ADMINISTRATION OF REVENUE LAWS. Revenue for local purposes in California is obtained through the levy of the general property tax on all forms of property except those reserved for exclusive taxation by the State and those exempt under the Constitution. Examination of the conditions surrounding the use of the general property tax in this and other States leads to these con- clusions: First, the equitable assessment of property is of tremendous social and economic importance; Second, equality and justice are lost by reason of the uni- versal practice of undervaluation by local assessors; Third, assessment at full value as required by law^ is essential, with a limited tax rate to protect assessors who obey the law; Fourth, such an assessment at full value is impossible without central supervision; and Fifth, California should create a State tax commission with power to require the uniform interpretation and adminis- tration of the law. A. The Importance of Equitable Assessments. The weaknesses of the present decentralized administration of local revenue laws chiefly aflfect the common forms of prop- erty, and thus come home to every taxpayer in the State. Common forms of property, as distinguished from corporate property, pay 85 per cent of the total taxes. State and local, col- lected in California, yet the methods of assessment and equaliza- tion in common use are inefficient and expensive, and absolutely prohibitive of that equality between individuals that is the founda- tion of a just tax system. It is in the local assessment that the germ of inequitable tax- ation finds its origin. Unless the initial assessment can be made fair and uniform, taxation develops gross abuses and deliberate tax-dodging becomes a common practice. The importance of the problem grows yearly, with the tre- mendous increases in local taxation. Between 1910 and 1914. the taxes levied on assessments made by a hundred or more local assessors, each interpreting and administering the law accord- ing to his individual notions, increased more than 60 per cent, or from approximately $47,000,000 to $76,000,000. These are large sums to be withdrawn from the State's wealth for the purposes of government. It is of utmost importance that such a great public burden be distributed as fairly as sound laws and scientific administration can achieve. / 10 V B. The Practice of Undervaluation. It is a matter both of record and of common knowledge that undervaluation is practiced by every local assessor in California. In this practice, for which (it is important to remember) the assessor cannot be held to blame, is found the "germ of inequit- able taxation" that has diseased the entire revenue system. An investigation made two years ago by the State Board of Equalization showed that the average ratio of assessed to true value in the State at large was 45.1 per cent. In some of the counties the average was as low as 25 per cent; in others it came to more than 50 per cent. No attempt was made to ascertain the variations within any county, but these, it may fairly be sur- mised, were at least as great as the variations between the several counties. The inevitable result of undervaluation is a great lack of uni- formity in the assessment of different kinds of property in the same county and the same kinds of property in the different counties. C. Equitable Assessment Must be at Full Value. Although of course it is theoretically possible, tax adminis- trators universally agree that it is practically impossible to se- cure uniformity of assessment, and, therefore, equality of tax- ation, except on the basis of actual value. The moment a frac- tional basis is introduced, each assessor becomes a law unto himself and an imperfect one, in spite of his own best eflForts. Uniformity is lost in the continual shifting of percentages and rates. The fact that in 47 States, including California, property is required by law to be listed at its actual value shows that assess- ment at actual value is generally considered fundamentally sound, and the only practicable means of securing equality of taxation between individuals. The Opinions of Leading Authorities. On the practice of undervaluation, all students of taxation agree that it is a cloak for the gravest abuses of the general property tax. The following expressions represent the views of three leading American authorities on the subject. "Nothing is practical, nothing is right and just but the use of full value. Any departure from full value as the sole aim leads to inequalities." — Professor Carl C. Plehn. "We are learning that assessment at the full value is the only means by which equality in individual assessments can be secured; and that in a community where the average valuation is 50 per cent, individual assessments may vary from 20 to 120 per cent of the true value of the property." — Professor Charles J. Bullock, Harvard University. "An equitable assessment cannot be made except at full value, and unless the assessment is at full value the in- 11 dividual taxpayer has no real protection agfainst over-assess- ment." — Edward L. Heydecker, Assistant Tax Commis- sioner, New York City. Limiting the Tax Rate. Raising the basis of assessment to actual value necessary re- quires the placing of some restraint upon the autliorities levying local taxes, to prevent them from using the augmented assess- ment roll to increase the levy. This problem can be met, as in other states, by a state-wide limitation upon tax rates, thus al- laying the fears of assessors and taxpayers, often expressed, that assessment at full value would add to the tax burden. D. Centralized Control of Assessments Necessary. In California it has been absolutely impossible to realize as- sessment at full value because of the decentralized administrative machinery. This fact alone furnishes the strongest possible argu- ment in support of the proposal to create a permanent State tax commission with power to assist and direct local assessors and compel them towards a uniform interpretation and administra- tion of the law. Undervaluation is not primarily the fault of the local assessor. Under the present system, no assessor in the State dares to de- part from the custom. On the one side he is bound by the cus- tom itself and by the fact that his constituents generally believe they are able to escape part of their taxes through undervaluation. On the other side, he is held down by the knowledge that the board of supervisors of his county, or the council of his town, would almost certainly use the larger roll to raise the amount of the levy, in the absence of any restraint. Between these two, the assessor is powerless, but with full control vested in a central commission and the taxing author- ities under statutory restraint, the way will be open to securing a measure of equality in assessments that can never be possible under the present system. Central control does not mean the removal of local elected assessors and the appointment of their successors. The laws of Minnesota, Kansas, Arizona, Wisconsin and other States give to the tax commission full authority over the machinery of as- sessment and equalization, but only in Ohio are the local as- sessors appointed instead of elected. No change in the method of selecting assessors is required to accomplish the ends desired in California. What Central Control Would Mean. Expressed positively, central control of the machinery of as- sessment and equalization of property values would mean (a) the uniform interpretation and administration of the law; (b) the assessment of all property at full value; (c) the protection of the willing and efficient assessor in his job; 12 (d) the elimination of the influence of local politics; (e) an end to the costly double assessment of the same prop- erty, as by a county assessor and a city assessor working in the same field; (f) the possible adoption of biennial or quadrennial assess- ments of real estate, instead of annual assessments, thus effecting a large saving to local taxpayers (local assess- ments now cost more than $1,000,000 a year); and (g) the uniform use of rules and standards supplied by the State commission. E. Creation of State Tax Commission. The literature of modern taxation, reciting the experience of other States, is filled with examples showing the efficiency of centralized assessing power, as in Wisconsin, Kansas, Minnesota, Ohio, etc., and the inefficiency of uncontrolled local assessments. The situation is tersely stated in the following paragraph from a report of the Minnesota Tax Commission: "The most hope for better administration seems clearly to point to centralization of assessment and administration of tax laws that shall be modified and amended from time to time to meet new conditions." In view of the conditions which have been shown to exist in California, the importance of improving the administrative ma- chinery cannot be emphasized too strongly. The most successful experience points unmistakably to the creation of a State tax commission. The responsibility of the State in the matter is not lessened by the fact that temporarily, at least, there is no State tax levied against local assessments in California. The United States Com- missioner of Corporations, in the introduction to a volume en- titled "Special Report on Taxation," published in 1913, writes on the subject: "This system (separation of State and local revenues) avoids inequalities incidental to the levying of a State rate on assessments, which in some counties may be above and in other counties below the State's average valuation, thus limiting the tax inequalities between individual parcels of propertv to such as mav exist within a given county, but it does not obviate the necessity for strong centralized State administration of tax laws, since no method of selec- tion has yet been devised which permanently guarantees a sufficiency of State revenue." Professor Bullock, the Harvard authority on taxation, concurs in this opinion. On the practice of undervaluation and its effect upon individual taxpayers, he writes: "Such a condition in local taxation is not a thing of in- diflFerence to the State at large; taxation is not a matter of purelv local concern. The propertv that is overburdened mav belong to a small minoritv that has no effective^ voice in local affairs. The State has an obvious dutv in the premises, which cannot be iustlv or honorablv evaded. Sep- aration has nowhere solved the problem of local taxation; 13 and, whatever its merits or demerits otherwise, does not relieve the State of its responsibility in this important matter." Further, on the subject of State control of local assessments by a central tax commission, Professor Bullock accurately meets the situation in California when he writes: "The experience of American States demonstrates beyond all doubt, cavil or contradiction that there never was and never can be a generally satisfactory assessment of property, incomes or business by purely local authorities. "Local administration can never give us a satisfactory system of taxation, and the co-operation of State author- ities has become absolutely indispensable. For this work the old-fashioned board of equalization is useless, State boards with ex-officio members wholly inadequate, and a permanent tax commission, composed of well-paid experts enioyine certainty of tenure, independence of action, and freedom from political influence, the only effective agency." Other authorities speak with equal force for a tax commis- tion with wide supervisory powers. Thomas S. Adams, member of the Wisconsin Tax Commission for many years, writes: "A strong tax commission is recognized by every au- thority as an indispensable part of the successful tax system." Professor Plehn goes even further, and would have the as- sessments made directly by the central commission, acting through appointed assessors. In an address at the Washington State Tax Conference held in Seattle last year, Professor Plehn said: "While defective definitions, and absence of classifica- tion have been responsible for many evils in the property tax in the past, the greater ones have arisen from weakness of administration. "The requirements for the assessor's office and its work directly imply: (i) a strong central State tax commis- sion. (2) appointed assessors responsible to the tax com- mission only, (.^) civil service rules, and the removal of the assessors and the tax commission as far as possible from political influences, and (4) pre-equalization like a pre-audit involving the standardization of assessment methods and the fixing of standard values by the central tax commis- sion." It is a significant fact that with the single exception of Cali- fornia, every American state that has made signal advances in the field of taxation in recent years has discarded its old-fashioned board of equalization in favor of an appointed tax commission. The list includes Massachusetts, New York, Ohio, Wisconsin, Michigan, Minnesota, Kansas, Oregon and 25 others. Other Functions of State Tax Commission. Except in a static commonwealth, no laws relating to taxation can be deemed permanent. Social and economic changes of vital importance are constantly taking place, and a tax system re- 14 quires perpetual investigation. It is the proper function of a State tax commission to keep abreast of the revenue problems and advise the Legislature and the public thereof. Regardless of the nature of the changes which it may be necessary to make in the California revenue system two years hence, it may be taken as a certainty, based on the experience of 33 States, that the new laws will be more successfully adminis- tered if placed in the hands of a body of men chosen for their technical knowledge and ability. 15 3. AS TO THE PENDING MEASURES. The problems presented in the foregoing discussion have long had the attention of certain of the State officials and members of the Legislature familiar with the situation, and plans for their solution have been under consideration for months. With the opening of the session in January, Senator Newton W. Thompson introduced three measures looking to the neces- sary improvement of the whole revenue system. These measures, which will be acted upon by the Legislature after the Constitu- tional recess, provide as follows: A. Full investigation of Revenue System. The first is a bill appropriating $75,000 to be spent under the direction of the Governor during the next two years in making a thorough investigation of the revenue system of California, both State and local, to the end that the Legislature of 1917 may be in possession of facts on which to act intelligently in equalizing corporation rates and revising the system. B. Authority to Amend Present System. The second is a Constitutional Amendment to be voted on in the next election, authorizing the Legislature in 1917 or in any subsequent year to amend Section 14 of Article XIII of the Con- stitution relating to the taxation of certain properties taxed ex- clusively for State purposes. This is purely an enabling act and does not commit the Legislature or the people to any particular method of taxation, while leaving intact the original Constitu- tional limitations upon legislative power. C. Creating a State Tax Commission. The third is a Constitutional Amendment abolishing the present elected board of equalization and creating a permanent State tax commission, to be appointed by the Governor and to have full power and authority over the revenue system, both State and local, in California, including the machinery of assess- ment and equalization. This measure is in harmony with the best economic thought and most successful experience, and is a necessary basis for other fiscal reforms which may appear ad- visable later. CALIFORNIA STATE TAX ASSOCIATION. The CALIFORNIA STATE TAX ASSOCIA- TION is a non-partisan, non-political organization devoted to promoting a wider public interest in the important subject of taxation. This Association was organized in 1913. The objects of the Association are "to correct existing evils and inequalities in taxa- tion; promote economy in public expenditures, both State and local, and to formulate and announce the most progressive economic thought and administra- tive experience available for the correct guidance of public opinion, legislative and administrative action on all questions pertaining to State and local tax- ation." OflScers President John S. Drum First Vice-President J. F. Sartori Second Vice-President M. L. Requa Secretary Dudley Cates Directors John S. Drum Allen G. Wright Allen Chickering B. F. Schlesinger George T. Klink Marshall Hale C. O. G. Miller San Francisco J, F. Sartori Geo. I. Cochran W. E. McVay W. W. Mimes H. W. O'Melveny Los Angeles M. L. Requa Oakland THK LiUKAKY UNIVERSITY OF CALIFORNIA LOS ANGELE3 tuiora ■ PAM PHIET BINDER ZI^Z Syrocuje, N. Y. Z:^— Stockton, Colif. SOUTHERN REGIONAL UBR^^^^^^^^^^^^^^ AA 001194 083