аfter stating the case as above reported, delivered the opinion of the court.
The question presented by this writ of error is whether lands in the State of Tennessee, which, pursuant to acts of Congress for the laying and collecting of direct taxes, are sold, struck off and purchased by the United States for the amount of the tax thereon, and' are afterwards sold by the United States for a larger sum, or redeemed by the former owner, are liable to be taxed, under authority of the State, while so owned by the United States.
The judgment of the Supreme Court of Tennessee rests upon the position that these lands, although lawfully purchased by the United States, and owned by the United States at the time of being taxed under the laws of the State, were not exempt from State taxation, because they had not been expressly ceded by the State to the United States.
¥e are unable to reconcile this position with a just view of the rights and powers conferred upon the national government by the Constitution of the United States. The importance of
In the words of Chief Justice Marshall, “ The United States is a government, and consequently a body politic and corporate, capable of attaining the objects for which it was created, by the means 'which are necessary for their attainment. This great corporation was ordained and established by the American people, and endowed by them with great powers for important purposes. Its powers are unquestionably limited; but while within those limits, it is a perfect government as any other, having all the faculties and properties belonging to a government, with a perfect right to use them freely, in order to accomplish the objects of its institution.”
United States
v. Maurice,
While the power of taxation is one of vital importance, retained by the States, not abridged by the grant of a similar power to the government of the Union, but to be concurrently exercised by the two governments, yet even this power of a State is subordinate to, and may be controlled by, the Constitution of the United States. That Constitution and the laws made in pursuance thereof are supreme; they control the constitutions and laws of the respective States, and cannot be controlled by them. The people of a State give to their government a right of taxing themselves and their property at its discretion. But the means employed by the government of the Union are not given by the people of a particular State, but by the people of all the States; and being given by all, for the benefit of all, should be subjected to that government only which belongs to all. All subjects over which the' sovereign power of a State extends are objects of taxation; but those over which' it does not extend are, upon the soundest principles, exempt from taxation. The sovereignty of a State extends to everything which exists by its own authority, or is introduced by its permission; but does not extend to those means which are employed by Congress to carry into execution powers conferred on that body by the people of the United States. The attempt to use the taxing power of a State on the means employed by the government of the Union, in pursuance of the Constitution, is itself an abuse, because it is the usurpation of a power which the people of a single State cannot give. The power to tax involves the power to destroy; the power to destroy may defeat and render useless the power'to create; and there is a plain-repugnance in conferring on one government a power to control the constitutional measures of another, which other, with respect to those very measures, is declared to be supreme over that which exerts the control. The States have no power, by taxation
Such are the outlines, mostly in his own words, of the grounds of the judgment delivered by Chief Justice Marshall in the great case of
McCulloch
v. Maryland, in which it was decided that a statute of the State of Maryland, imposing a tax upon the issue of bills by banks, could not constitutionally be applied to a branch of the Bank of the United States within that State.
In
Osborn
v.
Bank of United
States,
To guard against any misunderstanding of the scope and effect of the decision in
McCulloch
v.
Maryland,
Chief Justice Marshall added: “ This opinion does not deprive the States of any resources which they originally possessed. It does not extend to a tax paid by the real property of the bank, in common with the other real property within the State, nor to a tax imposed on the interest which the citizens of Maryland may hold in this institution, in common with other property of the same description throughout the State.”
But the only taxes thus spoken of as valid are those upon
Not only did each of the counsel for the State of Maryland, Mr. Hopkinson, Mr. Jones, and Mr. Martin, make it a cornerstone'of his argument in support of the validity of the tax on the bank, that the property of the United States as such was not exempt from taxation by the State in which it was situated.
Mr. Webster, in opening the argument against the validity of the tax, said: “ The government of the United States has itself a great pecuniary interest in this corporation. Can the States tax this property ? Under the Confederation, when the national government, not having the power of direct legislation, could not protect its own property by its OAvn laws, it was expressly stipulated, that
‘
no impositions, duties or restrictions should be laid by any State on the property of the United States.’ Is it supposed that property of the United States is now subject to the power of the State governments in a greater, degree than under the Confederation ? If this power of taxation be admitted, what is to be its limit? The United States have, and must have, property locally existing in all the States; and may the States impose on this property, whether real or personal, such taxes as they please ? ”
Mr. Pinkney, in the closing argument on the same side, said: “ There is no express provision in the Constitution, which exempts any of the national institutions or property from State taxation. It is only by implication that the army, and navy, and treasure, and judicature оf the Union are exempt from State taxation. Yet they are practically exempt; and they must be, or it would be in the power of any one State to destroy their use. Whatever the United States have a right to'
Chief Justice Marshall, in delivering judgment, covered the whole ground by saying: “ If the States may tax one instrument, employed by the government in the execution of its powers, they may tax any and every other instrument. • They may tax the mail; they may tax the mint; they may tax patent rights; they may tax the papers of the custom-house; they may tax judicial process; they may tax all the means employed by the government, to an excess which would defeat all the ends of government. This was not intended by the American people. They did not design, to make their government dependent on the States.
“ Gentlemen say, they do not claim the right to extend State taxation to these objects. They limit their pretensions to property. But on what principle is this distinction made ? Those who make it have furnished no reason for it, and the principle for which they contend denies it.”
So in
Weston
v.
City Council of
Charleston, the exemption of the public lands, while owned by the United States, from State taxation was assumed; both in the argument of counsel that a' State tax on stock issued by the United States to individuals was equally valid with a tax on lands after they had been sold by the United States to private persons; and in the answer made by Chief Justice Marshall: “ The distinction is, ' we think, apparent. When' lands are sold, no connection remains between the purchaser and the government. The lands purchased become a part of the mass of property in the country, with no exemption from common burthens.”
The United States do not and cannot hold property, as a monarch may, for private or personal purposes. All the property and revenues of the United States must be held and applied, as all taxes, duties, imposts and excises must be laid and collected,
“
to pay the debts and provide for the common
The more thoroughly the proceedings by which the States became members of the Union, either by joining in establishing' the Federal. Constitution, or by admission under subsequent acts of Congress, are examined, the more strongly they confirm the same view.
In the Articles of Confederation of 1778, it had been expressly stipulated that “no imposition, duties or restriction shall be laid by any State on the property of the United States.” And in the articles which the Ordinance of 1787 for the government of the Northwest Territory declared should “ be considered as articles of compact between the original States and the people and States in said Territory, and forever remain unalterable, unless by common consent,” it had been provided that “ no tax shall be imposed on lands the property of the United States.” Constitutions and Charters, 8, 432.
The Articles' of Confederation ceased to exist upon the adoption of the Federal Constitution; and the Ordinance of 1787, like all acts of Congress for the government of the Territories, had no force in any State after its admission into the Union under that Constitution.
Permoli
v.
First Municipality of New
Orleans,
The Constitution creating a more perfect union, and increasing the powers of the national government, expressly authorized the Congress of the United States “to lay and collect taxes, duties, imposts and excises, to pay the debts and provide for the common defence and general welfare of the United States; ” “ to exercise exclusive legislation over all places pur
Nor was any provision on this subject inserted in the acts of Congress for the admission into theUnionofYermontin 1791; of Kentucky, formed out of part of Yirginia, in the same year; of Tennessee, formed out of part-of North Carolina, in 1796-; of Maine, formed out of part of Massachusetts, in 1820; of Texas, previously a foreign and independent republic, in 1815 ; or of West Yirginia, formed out of part of Yirginia, in 1862. Constitutions and Charters, 1875, 646, 1676, 810, 1764, 1992.
The first State formed out of territory not within the jurisdiction of an existing State was Ohio, admitted into the Union in 1802, under an act of Congress containing three propositions, offered by Congress for her acceptance or rejection, and which were accepted by the State,-namely, that one section of land should be granted to each township for the use of schools, that certain salt springs should be granted to the Statе, and that one twentieth part of the net proceeds of lands lying within the State and sold by Congress after June 30,1802; should be applied to the. laying out of public roads : “ Provided always, that the three foregoing propositions herein offered are on the conditions that the convention of the said State shall provide, by an ordinance irrevocable without the consent of the United States, that every and each tract of land sold by Congress from and after the thirtieth day of June next shall be and remain exempt from any tax laid by order or under authority of the State, whether for State, county, township, or any other purpose whatevér, for the
The acts for the admission of Indiana in 1816, and Illinois in 1818, contained similar provisions to those in the act for the admission of Ohio. Constitutions and Charters, 499, 438.
Neither of these three acts contained any stipulation for the exemption of the lands of the United States from State taxation ; but each, assuming that exemption as undoubted, and requiring no affirmance, so long as the United States owned the lands, only provided fоr its continuance for five years after the United States should have sold,them, and thereby ceased to have any interest in them.
The statement of Mr. Justice McLean, in a case in the Circuit Court concerning land in Illinois, “ In the admission of new States into the Union, compacts were entered into with the Federal Government, that they would not tax the lands of the United States,” was therefore, as applied to the case before him, an inadvertence, which impairs the weight of his dictum, based upon it, that “this implies that the States had power to tax such land, if unrestrained by compact.”
United States
v.
Railroad Bridge Co.,
The question in issue in' that case was not of the State’s right of taxation, but of its right of eminent domain for the construction of roads and bridges. The decision of the learned justice in favor of the validity of the exercise of that right J>y a State over lands of the United States, without the consent of the United States, manifested either by an express act of Congress, or by the assent of a-department or officer,vested by law with the power of disposing of lands of the United States, appears to have been based'upon the theory that the United Stаtes can hold land as a private proprietor, for other than public objects, and upon a presumption of the acquiescence of Congress in the State’s exercise of the power as tending to increase the value, of the lands ; and it finds some support in dicta of Mr. Justice Woodbury, in a case in which, however, the exercise of the, power by the State was adjudged to be unlawful:
United States
v. Chicago,
Upon the question of taxation of lands of the United States by the State of Illinois, two well considered opinions of the Supreme Court of that State are worthy of reference in this connection. In one of them, it was held that a lot-of land 'in Chicago, owned by the United States, used by them for a custom-house, post-office and court-house, and which the legislature of the Statе had consented might be so used, and had ceded jurisdiction over, was not liable to assessment by the municipal authorities, under a statute of the State, for the amount of the benefit to the land from the laying out of a highway ; and the court said: “Nor under our system of government can the States tax the general government, its agents or property, nor can the general government, tax the States, their agents or property.” “ A municipal corporation has no power to assess or exact from the State or the general government any sum for benefits conferred. The power to levy taxes or impose assessments for benefits can only be exercised on the governed, and not on the governing power, whether State or Federal.” Fagan v. Chicago, 84 Illinois, 227, 233, 234. In the other case, it was directly, adjudged that from the very nature of the relation between the Federal and State governments, and without regard to any supposed compact contained in the Ordinance of 1787, or in any act of Congress, no property lawfully vested in the United States could be taxed by the State, and that therefore land sold, purchasеd and held by the United States for nonpayment of direct taxes was exempt from State taxation. People v. United States, 93 Illinois, 30.
In Louisiana, the first territory acquired by the United States from a foreign country, the act of March 26,1804, establishing a territorial government over it by the name of the Territory of Orleans, provided that the legislative power should be vested in the governor and legislative council, and “ shall extend to
On April 28, 1806, John Breckenridge, of Kentucky, Attorney General of the United States, gave to Mr. Madison, Secretary of State, a brief and comprehensive opinion, not based upon the restrictions imposed by the territorial act on the legislative council, or upon any considerations peculiar to Louisiana, but upon general principles applicable to all the States and Territories alike, and therefore, and as the earliest legal opinion upon the question, worthy of being quoted in full. It is in these words“ I am of opinion that there rests no power in the city council, nor in any department of the government of Orleans, to tax the property of the United States within that Territory. I believe the exercise of such power has never been before attempted in any part of the United States, and I think the general government ought not to admit the'principle. Laying the tax will be harmless, for I see no meant by which the payment of it cap be enforced.” • 1 Opinions of Attorneys General, 157.
By the conditions of the acts of 1811 and 1812 under which the State of Louisiana was admitted into the Union, “the people inhabiting the said Territory do agree and declare that they forever .disclaim all right or title to the-waste or unappropriated lands l-ying within the said Territory, and that the same shall be and remain at the sole and entire disposition of the United States, and moreover that each and every tract of land sold by Congress shall be and remain exempt from any tax laid by the order or under the authority of the State, whether for State, county, township, parish, or any оther purpose whatever, for the term of five years from and after the respective days of the sales thereof,” “ and that no taxes shall be imposed on lands the property of the„-United States.” Constitutions and Charters, 699, 70Ó, 710.
Upon the admission of every other State into the Union, the
In, the acts for the admission of Mississippi in 1817, Alabama in 1819, Missouri in 1820, Arkansas in 1S36, Michigan in 1837, Iowa in 1845 and 1846, Wisconsin in 1847, Minnesota in Í857, and Oregon in 1859, the words are “ no tax shall be imposed on lands the property of the United States,” or words of exactly the same meaning. Constitutions and Charters, 1053, 31,1103, 118, 995, 535, 552, 2027, 1028, 1508. In the acts of 1864 for the admission of Nevada, of 1864 and 1867 for the admission of Nebraska, and of 1875 for the admission of Colorado, the expression is somewhat fuller, “no tax shall be imposed by the State on lands or property therein, belonging to, or which may hereafter be purchased by, -the United States.” Ib. 1246, 1202" 1213, 218.
Florida was admitted in 1845, upon the express condition that it should never interfere with the primary disposal of the public lands lying within it, “ nor levy any tax on the same whilst remaining the property of the United States; ” and California in 1850, “ upon the express condition that the people of said State, through their legislature or otherwise, shall never interfere with the primary disposal of the public lands within its limits, and shall pass no law and do no act whereby the title of the United States to, and right to dispose of, the same shall be impaired or questioned; and that they shall never lay any tax or assessment of any description whatsoever upon the public domain of the United States.” Constitutions and Charters, 332, 208.
In the debate in the Senate in June, 1850,- on the act for the admission of California, a motion to amend the act by requiring California before her admission to pass in convention an ordinance providing, among other things, “ that she relinquishes all title or claim to tax, dispose of, or.in any way to interfere with the primary disposal by the United States of the public domain
The Supreme Court of the State of California appears at one period to have assumed, that the exemption of the lands of the United States from taxation depended upon the terms of the act of Congress admitting the State' into the . Union, or upon the statutes of the State.
People
v. Morrison, 22 California, 73;
People
v.
Shearer,
30 California, 645. But in later .cases it has taken broader ground, and has defined the meaning of
The recital, in the ordinance prefixed to the Constitution of Kansas, that the State would possess the right to tax the lands owned by the United States within its limits, and the conditional relinquishment of that right, were not assented to by Congress; and Kansas was admitted into the Union in 1861, only upon the passage by its legislature of another ordinance, irrevocable without the consent of Congress, accepting certain propositions, in which it was provided that the State should never interfere with the primary disposal of the soil within the same by the United States, and should never tax the lands of the United States. Constitutions and Charters, 613; Act of Congress of January 29, 1861, ch. 20, § 3, 12 Stat. 127; Joint Resolution of Legislature of Kansas of January 20,1862, Compiled Laws of Kansas, 1862, p. 84. In 1865 the Supreme Court of the State, discussing and upholding the validity of a State tax upon Indian lands, said: “ If the title to the lands be in the United States, they are not taxable. Not only are the lands of the general government exempt from taxation by express stipulation on the part of the State, but without such agreement they would not be liable to be taxed. The irrevocable ordinance of the legislature is merely the expression of what the law would have been without it.”
Blue Jacket
v.
Johnson County Commissioners, 3
Kansas, 299, 348, reversed by this court in
The taxation by the State of Kansas, the validity of which
It cannot be doubted that the provisions whibh speak the exemption of property of the United States from taxation, in the various acts of Congress admitting States inte the Union, are equivalent to each other; and that, like the other provision, which often accompanies them, that the State “ shall not interfere with the primary disposal of the soil by the United States,” they are but declaratory, and confer no new right or power upon the United States.
In
Gibson
v.
Chouteau,
Upon the admission of a State into the Union,-the State
In
McGoon
v.
Scales,
The eases in which it has been held that public lands? granted by the United States to a railroad company, continue to be exempt from State taxation so long as the costs of survey have not been paid and patents have not been issued, stаnd upon equally broad ground.
Railway Co.
v.
Prescott,
Even in the courts of the several States, the decided and increasing preponderance of authority is in favor of the absolute exemption of all property of the United States from.State taxation.
The only instances that have been brought to. our notice, in which a State court has countenanced the right of a State to tax any property of the United States, are the judgment now under review; some remarks in Louisville v. Commonwealth, 1 Duvall, 295, in which the only matter in issue, was a tax laid by the State of Kentucky on property of one of its own muni7 cipal corporations; a dictum .in People v. Shearer, 30 California, 645, 658; and two cases in the Supreme Court of Pennsylvaniа, not found in the regular series of its reports, but' only in law periodicals, and in a reprint of one of them in a collection of nisi prius and other cases. Commonwealth v. Young, 1 Hall’s Journal of Jurisprudence, 47; S. C., Brightly, 302; Roach v. Philadelphia County, 2 Am. Law Journal (N. S.), 444.
In
Commonwealth
v. Young, decided in 1818, a person employed by the President of the United States, with the author
In Roach v. Philadelphia County, above cited,.a tax on the United States mint was held valid, but no opinion is reported.
On the other hand, the necessary exemption of all the prop- ' erty of the United States from State taxation has been recognized by the highest courts of Illinois, California and Kansas, in the cases already -cited.-; and by those of Virginia, Connecticut, Iowa and Wisconsin.
Western Union Telegraph Co.
v.
The legislatures of most of the States hare affirmed the same principle, by inserting in their general tax acts an exemption of property belonging to the United States. Such a provision, as has been well observed by the Supreme Court of -Connecticut in
West Hartford
v.
Water Commissioners,
above cited, is not the foundation of the exemption, but is inserted only from abundant caution, and because the assessment of taxes is to be made by local officers skilled in the valuation of property, but presumably unlearned in legal distinctions.
An examination of the existing statutes óf the several States (cited in the margin
*
) shows this result: In at least twenty-
General tax acts of a State are never, without the clearest words, held to include its own property, or that of its muni’ci-
In short, under a republican form of government, the whole ' property of the State is owned and held by the State for public uses, and is not taxable, unless the State wfijch owns and holds it f or those -uses clearly enacts that it shall share the burden of taxation with other property within its jurisdiction..
The only uncertainty in the decisions of this court upon the subject is to be found in two cases, the one argued at December term, 1847, and the other at December term, 1848, and both reargued by order of the court and decided at December term, 1849, by an equal division of the judges, and therefore not re- ■ ported, but which appear by the records to have been as follows:
The first of those cases Avas United States v. Portland, which, as agreed in the statement of facts upon Avhich it was submitted to the decision of the Circuit Court of the United States for the District of Maine, Avas an action brought by the United States against the City of Portland to recover back the amount of taxes assessed for county and city purposes, in conformity with the statutes of Maine, upon the land, Avharf and building OAvned by the United States in that city. The building had been erected by the United States for a custom-house, and had always been used for that purpose, ap.d no other. The land, building and Avharf were within the legislative jurisdiction of the State of Maine, and had always been so, nоt having been purchased by the United States with the consent of the legislature of the State. The case Avas heard in the Circuit Court at May term 1845, and Avas brought to this court upon a certificate of division of opinion betAveen Mr. Justice Story and Judge Ware on several questions of law, the principal one of which Ávas, Avhether the building, land and Avharf, so OAvned and occupied by the United States, were legally liable to taxation ; and this court, being equally divided in opinion on those questions, remanded the case to the Circuit Court for further proceedings. The action therefore failed. The legislature of Maine having meanwhile, by the statute of 1846, ch. 159, § 5, provided that the property of the United States should be exempted from taxation, the question has-never been reneAved.
The division of opinion here in those cases was evidently the reason for the guarded form in which the general doctrine was stated, while those cases were pending, by Mr; Justice Wood-bury in
United States
v. Ames, 1 Woodb.
&
Min. 76, 85, and presently afterwards by Mr. Justice Grier in United.
States
v.
Weise,
2-Wall. Jr. 72, and by Mr. Crittenden, as Attorney General, in 5 Opinions of Attorneys General, 316, as well as by Mr. Justice McLean, when, in delivering the judgment of this court upholding the validity of a State law taxing all money or exchange brokers, he said: “ The taxing power of a State is one of its attributes- of sovereignty. And where there has been no compact with the Federal government, or cession of jurisdiction for the purposes specified in the Constitution, this power reaches all the property and business within the State, which .are not properly denominated the means of the general government.”
Nathan
v. Louisiana,
But the two decisions above mentioned, by an equal division of this court, and with no evidence of the reasons which influenced any of the judges, have no weight as authority in any other case; and we have no hesitation.in saying that a tax imposed under authority of a State upon a building used as a custom-house or a mint, and the land on which it stands, owned by the United States, cannot be supported, consistently with the principles affirmed in
McCulloch
v.
Maryland,
especially in
The liability of the property of the Pacific Railroad Companies to State taxation has been upheld,.on the distinction stated in
McCulloch
v. Maryland,
The cases in which this court has held that the United States have no power under the Constitution to tax either the instru-mentalities or the property of a State have a direct and important bearing upon the question before us.
In
Collector
v.
Day,
• Applying the same principles, this court, in
United States
v.
Railroad Co.,
The latest utterance of this court upon this subject is in a case decided at the present term,-in which Mr. Justice Bradley, delivering the judgment of the whole court, upon a question of the extent of the-taxing power of a State, said : “We take it to be a point settled beyond all; contradiction or question, that
The United States acquired the title to aE the land now in question under the express authority of acts of Congress, and by proceedings the validity of which is clearly established by a series of decisions of this court. Acts of June 7, 1862, ch. 98, § 7, 12 Stat. 423; June 8, 1872, ch. 337, § 4, 17 Stat. 331, and February 8, 1875, ch. 36, § 26, 18 Stat. 313;
Bennett
v. Hunter,
The question whether the taxes laid under authority of the State can be collected in this suit depends upon the question whether they were lawfully assessed.. But all the аssessments were unlawful, because made while the land was owned by the United States. The assessments, being unlawful, created no lien.' upon the land. Those taxes, therefore, cannot be collected, even since the plaintiffs in error have redeemed or purchased the land from the United States.
Whether the Supreme Court of Tennessee rightly construed the provisions of the Constitution and'Statutes of the State as not exempting from taxation land belonging to the United States, exclusive jurisdiction over which had not been ceded by the State, is quite immaterial, because, for the reasons and upon the authorities above stated, this court is of opinion that neither the people nor the legislature of Tennessee had power, by constitution or statute, to tax the land in question, so Jong as the title remained in the United States. ,
The result■ is, that the judgment of the Supreme Court of the State of Tennessee must be reversed, and the ease remanded to that court for further proceedings in conformity with this opinion.
Notes
The express exemption of property of the United States in the general tax acts of eаch State is as follows :
Alabama. “ All property belongingto the United States.” Code 1876, §358.
Arkansas. “ All property, whether real or personal, belonging exclusively to the United States.” Digest 1874, § 5055.
California. “■ The property of the United States.” Political Code 1872, § 3607.
Colorado. None. Gen. Stat. 1883, § 2815.
Connecticut. “ All property belonging to the United States.” Gen. Stat. 1875; tit. 12, chi 1, § 12.
Delaware. “ Property belonging to the United States.” Rev. Stát. 1874* ch. 11, § 1.
Florida. “All property, real and personal, of the United States.” Digest 1872, ch. 138, § 4.
Georgia. “All property specially exempted by the Constitution of the United States.” “All lands, mines and minerals belonging to the United States.” Code 1873, § 798. “All public property.” Code 1882, § 798.
Illinois. 1 ‘ All unentered government lands, all public buildings dr structures of whatever kind, and the contents thereof, and the land on which the same are located, belonging to the United States.” Rev. Stat. 1880, ch. 120, § 2.
Indiana. “ The property of the United States.” Rev. Stat. 1881, § 6276.
Iowa. “ The property of the United States.” Code 1873, § 797.
Kansas. “All property.belonging exclusively to the United States.” Stat. 1876, ch. 34, § 3.
Kentucky. “ The property of the United States, used for custom-houses, post-offices, docks, ship-yards, forts, arsenals or.barracks.” Gen. Stat. 1883, ch. 92, art.-1, § 3.
Maine. “ The property of the United States.” Rev. Stat. 1883, ch. 6, § 6.
Maryland. “ Property belonging to the United States.” Rev. Code 1878, art. 11, § 3.
Massachusetts. “The property of the United States.” Pub. Stat. 1882, ch. 11, § 5.
Michigan, “All the property of the United States.” Compiled Laws 1871, eh. 21, § 5.
Minnesota. “ All property, whether real or personal, belonging exclusively to the United States.” Stat. 1878, ch. 11, § 5.
Mississippi. ‘ ‘ All property, real or personal, belonging to the United States.” Rev. Code 1871, § 1662.
Missouri. “Lands and lots, public buildings and structures, with their furniture and equipments belonging to the United States.” Rev. Stat. 1879, § 6659.
Nebraska. “ The property of the United States.” Gen. Stat.1873, ch. 66, § 1.
Nevada. “All lands or other property of the United States.” Compiled Laws 1873, c-h. 98, .§ 4.
New Hampshire. “ The lots of land selected and purchased in this State by the United States for the purpose of erecting light-houses and other public buildings, with the buildings thereon.” Gen. Laws 1878, ch. 53, § 2.
. New Jersey. “ The property and the bonds and other securities of the United States.” Rev. Stat. 1877, p. 1151, § 5.
. New York. “1. .All property, real or personal, exempted from taxation by the Constitution of this State, or under the Constitution of the United States. 2. All lands belonging to this State, or the United States.” Rev. Stat. 1846, pt. 1, ch. 13, tit. 1, § 4.
‘ North Carolina. Parcels of land, containing, not more than twenty acres each, purchased by the United States from any individual or corporation, and held “ for the purpose of erecting thereon light-houses, light-keeper’s dwellings, life-saving stations, buoys and coal depots, and buildings connected therewith.” Code 1883, §§ 3080; 3082.
Ohio. “All property, whether real or personal, belonging exclusively to the United States.” Rev.. Stat. 1880, § 2732.
Oregon. “ All property, realand personal, of the United States.” Oeperal Laws 1874, ch. 57, § 4.
Bhode Island. “Lands ceded or belonging to the United States.” Pub. Stat. 1882, ch. 41, § 2.
South Carolina. “ All property owned exclusively by the United States.” Bev. Stat. 1882, § 169.
Tennessee. “ All property belonging to the United States, used exclusively for public purposes.” Stat. 1883, ch. 105, § 2 ; .Code 1884, § 601.
Texas. “ All property, whether real or personal, belonging exclusively to the United States. ” Bev. Stat. 1879, art. 4673.
Vermont. “ Beal and personal estate owned by the United States.” Bev. Laws 1800, § 270.
Virginia. None. Code 1873, ch. 33, § 14
West Virginia. “Property belonging, to the United States.” Code 1868, ch. 29, § 43.
Wisconsin. “Property owned exclusively by the United States.” Bev. Stat. 1878, § 1038.