Pente taxation is not a prerequisite to a valid assessment. cost v. Stiles, 5 Okla. 500 (49 Pac. Rep. 921). Hill's Ann. Or. Laws, § 2782, empowering county courts to correct errors in assessment rolls, does not allow them to strike property from rolls as exempt from taxation. Portland University v. Multnomah Co., 31 Or. 498 (50 Pac. Rep. 532). Wis. Rev. Stat., 1045, 1048, construed and applied-separate assessment of distinct parcels or lots of land. Neu v. Voege, 96 Wis. 489 (71 N. W. Rep. 880). Applying R. I. Pub. Stat., ch. 42, § 11, providing that personal property, for purposes of taxation, shall include "machines of all sorts propelled by steam," it is held that electric dynamos which are propelled by steam for the purpose of generating electricity for an electric plant, which may be easily removed from the real estate by the unscrewing of bolts, and an electric switch board with connecting wires used in connection with such plant which may be removed without injury to the realty, are personal property. It is also held that the wires and poles used for conveying electricity from such plant, some of which are set on private property and some on public highways are not fixtures to the lot on which the electric light is generated or appurtenant thereto, for the purpose of taxation as real estate although they cannot be assessed as personal property because they are not within the class of such property enumerated by the statute for taxation. Newport Illuminating Co. v. Tax Assessors, 19 R. I. 632 (36 Atl. Rep. 426; 36 L. R. A. 266). Sec. 899. Assessment of taxes-In whose name assessment should be made. The assessment in the name of a joint owner with words additional to the name indicating clearly enough who are the other joint owners, is not an invalid assessment. Hood v. City of New Orleans, 49 La. 1461 (22 So. Rep. 401). An assessment in the name of a deceased person is void. La. Laws 1890, Act No. 106, construed and applied. Cucullu v. Brakenridge Lum. Co., 49 La. 1445 (22 So. Rep. 409). But it is held that an assessment of property made in the assessment year of the owner's death, in his name and in existence when he died, will bind his heir and support a tax sale, under La. Laws 1884, Act No. 82 Clifford v. Michener, 49 La. 1511 (22 So. Rep. 811). An assessment to "Henry Loose and to all owners and claimants known and unknown," is invalid, and a tax deed reciting such an assessment is void. Z. Russ & Sons Co. v. Crichton, 117 Cal. 695 (49 Pac. Rep. 1043). Where, by the terms of the lease, structures erected by the lessee are to become the property of the lessor upon the termination of the lease, for the purpose of taxation they will be treated as the property of the lessor from the time of their construction. Bartlett, J., dissenting. People v. Barker, 153 N. Y. 98 (47 N. E. Rep. 46). Under the tax laws of Maryland, a lessee of premises for 99 years is treated as owner for the purposes of taxation. Textor v. Shipley, 86 Md. 424 (38 Atl. Rep. 932). extrinsic evidence to apply Sec. 900. Assessment of taxes-Description of property. A tax sale based upon an assessment, which does not contain any description of the property, conveys no title. Petit v. Flint & P. M. R. Co., 114 Mich. 362 (72 N. W. Rep. 238). Tex. Rev. Stat. 1895, art. 5076, prescribing the requisites of an assessment for state and county taxes, as to the description of the property, does not apply to assessments for city taxes. The description is sufficient when it furnishes the means by which property can be identified from the description itself or by the use of that description to the property. 90 Tex. 468 (39 S. W. Rep. 567). 70 Tex. 641 (8 S. W. Rep. 528); Fowler v. People, 93 Ill. 116; Woodside v. Wilson, 32 Pa. St. 52; Driggers v. Cassady, 71 Ala. 529; Judd v. Anderson, 51 Ia. 345 (1 N. W. Rep. 677; Allen v. Inhabitants of Wood. bridge Tp., 42 N. J. L. 401. A description of property in the assessment roll as it is described in a partition and is on record, is sufficient. Bristol v. Murff, 49 La. 357 (21 So. Rep. 519). An assessment of lands properly designated according to an official plat is not invalidated by the fact that they are referred to as fractional lots. Noyes v. King Co., 18 Wash. 417 (51 Pac. Rep. 1052). A description on an assessment roll as "lot frontage 78 feet, east side of Spring street between Third and Fourth streets, bounded north by Hunter, south by Morsch," was held void for indefiniteness. and parol evidence was held inadmissible to ascertain what particular tract or lot the assessor had in mind when making the assessment. Harvey v. Meyer, 117 Cal. 60 (48 Pac. Rep. 1014). A description as "V. C. N. E. Cedar & Tennessee," is insufficient. Smith v. Cox, 115 Ala. 503 (22 So. Rep. 78). Particular description held sufficient, Hood v. City of New Orleans, 49 La. 1461 (22 So. Rep. 401); insufficient, Anderson v. Post, Tenn. (38 S. W. Rep. 283). Sec. 901. Assessment of taxes-Omission of property-Errors in valuation-Boards of equalization. Construing and applying Minn. Gen. Stat.1894, § 1888, providing that in an application of the state for judgment for the amount of taxes levied against land, no omission of any of the things provided by law, etc., "shall be a defense or objection to the taxes appearing upon a piece or parcel of land unless it be also made to appear to the court that such omission has resulted to the prejudice of the party objecting, and that the. taxes against such piece or parcel of land have been partially, unfairly and unequally assessed; and in such case, but no other, the court may reduce the amount of taxes upon such piece or parcel of land," it is held that if the assessment of a taxpayer's land is impartial, equal and fair, compared with the average valuation of other lands generally (except particularly omitted or undervalued tracts) in the same taxing district, the fact that certain particular properties have been intentionally and willfully omitted from the tax lists, or intentionally and willfully undervalued, is no defense, either partial or total, to such an application. In re Taxes Delinquent in St. Louis Co., 71 Minn. 283 (73 N. W. Rep. 970). The omission to tax the town poor farm, the halls where town meetings are held, a small parcel of land on which the engine house stands, and the land on which the county court house stands, does not vitiate and make invalid the entire assessment of taxes made by the town. Inhabitants of Dover v. Maine Water Co., 90 Me. 180 (38 Atl. Rep. 101). A statute (Minn. Gen. Laws 1893, ch. 151) which provides for the taxation of property undervalued or unlawfully omitted from assessment, and for reassessment, where there has been a gross undervaluation of such property, is constitutional. In re Taxes for Itasca Co., 68 Minn. 353 (71 N. W. Rep. 265). See An assess opinion for extensive discussion of this question. ment of the improved real estate of a railroad in excess of the cost of reproducing such property in the condition existing at the time of the assessment, based upon an estimate of its value, as a part of a valuable railroad line by considering the cost, rentals and earnings of the entire line, is erroneous. People v. Clapp, 152 N. Y. 490 (46 N. E. Rep. 842; 39 L. R. A. 237). Under Hill's Ann. Or. Laws, §§ 2778, 2779, the board of equalization has power to increase or decrease valuations, to correct an assessment if property is assessed more than once or in the name of a person not the owner; to add to the roll property omitted by the assessor; but it has no power to determine whether property is exempt from taxation. Portland University v. Multnomah Co., 31 Ore. 498 (50 Pac. Rep. 532). Sec. 902. Priority of lien for taxes-Personal property taxes-Apportionment of tax lien to aid other lienholders. A lien for taxes has priority over a vendor's lien acquired before they were assessed. Thomas v. Jones, 94 Va. 756 (27 S. E. Rep. 813). The same is true as to judgment liens. Commonwealth v. Ashlin's Admr, 95 Va. 145 (28 S. E. Rep. 177). In North Corolina, it is held that a mortgagee's lien is subject to the lien for taxes and that he must pay them if the mortgagor does not, and that he is barred by a sale of the land for taxes without notice from the sheriff. Acts 1891, ch. 326, § 73, applied. Powell v. Sikes, 119 N. C. 231 (26 S. E. Rep. 38). Conn. Gen. Stat., 3890, 3896, do not make a limitation of the time beyond which a tax cannot be collected from a tax debtor, but fix the time beyond which the tax lien shall not have precedence over other liens. White v. Town of Portland, 68 Conn. 293 (36 Atl. Rep. 46). Applying Iowa Code, § 865, which makes taxes assessed on personalty a lien on the land of the persons assessed, it is held that such lien is subject to previous mortgage liens. Given, J., dissenting. Bibbins v. Polk Co., 100 Ia. 493 (69 N. W. Rep. 1007). Following, Bibbins v. Clark, 90 Ia. 230. See Ballards' Law of Real Property, Vol. III, §§ 722-726. Applying Cal. Pol. Code, §§ 3716, 3717, 3788, it is held that the lien for one's personal property tax is superior to that of a prior mortgage on the land. California Loan & T.Co. v. Weis, 118 Cal. 489 (50 Pac. Rep. 697). Under S. Dak. Laws 1891, ch. 14, §§ 96, 100, a lien for taxes upon personal property cannot be enforced against the real estate of the owner, until the county treasurer makes his return showing that he is unable to find personal property with which to satisfy such taxes; and a sale made in violation of this statute is invalid as against a prior mortgagee of the land. Under § 115, such a mortgagee may redeem from such a sale without paying the mortgagor's personal taxes. Buell v. Boylan, 10 S. Dak. 180 (72 N. W. Rep. 406). Where two creditors of a common debtor who is insolvent, each has, relatively to the other, the highest lien upon distinct parcels of real estate belonging to such debtor, and there are outstanding, against the latter, tax executions issued generally against him in personam, and binding both parcels of the realty, the burden of discharging the liens of these executions should as a general rule, upon equitable principles, be apportioned between the two lien creditors, by making each of the two pieces of property liable ratably for its proportion of the whole amount of the taxes, according to the respective valuations at which the property was assessed and returned for taxation. Brooks v. Matledge, 100 Ga. 367 (28 S. E. Rep. 119). Sec. 903. Lien for taxes-Statutes construed. Where proceedings to levy drainage assessments are had in the proper court under a statute (Ind. Laws 1883, p. 173, § 1), giving it jurisdiction over the land described in the petition "and power to fix a líen thereon if they are described as belonging to the person who appears to be the owner according to the last tax duplicate or record of transfer kept by the auditor of the county where the same is situate," a lien may be decreed against the land, as against the actual owner, although his name does not appear on the records. Reed v. Kalfsbeck, 147 Ind. 148 (45 N. E. Rep. 476). Applying S. Dak. Laws 1891, ch. 14, § 96, which makes taxes upon real property a" perpetual lien thereupon," it is held that when a sale of land for taxes is made and the property bid in by the county, the lien of the county is not thereby extinguished. Rochford v. Fleming, 10 |