It is a fundamental principle of our law that notice to taxpayers is necessary for a valid assessment, and there must be an opportunity to apply for correction. There is a notion quite commonly entertained and absolutely erroneous, that a board to hear complaints can be so constituted that it can secure a fair assessment. No board for the correction or review of assessments has ever existed that can do very much to correct a poor assessment. In the City of New York there are over 480,-000 separately assessed parcels of real estate. The greatest number of applications for correction since the consolidation of the city has been about 10,000, or only a little over two per cent of the whole number. With so large a number of applications as 10,000, it is almost physically impossible to give to each application the attention it deserves, and this statement is made with full knowledge of the fact that not more than one application in five has any merit. If all the 10,000 had merit, and all could be acted upon with sufficient time and intelligence, there would then be corrections as to only two per cent of the total number of assessments. In spite of the fact that a board of review has very little value as a means of correcting a poor assessment, it may have very great value indeed in performing the most important function of securing a better assessment the following year if the board of review is composed of the same men who direct the work of the assessors. In some cities, the board of review has nothing to do with the assessment they are called upon to correct, and the experience they gain is practically thrown away, whereas the experience gained in hearing complaints and passing upon objections is of the utmost value to those who direct the work of making the next assessment. Where the assessing department has a single administrative head or is directed by a board, the man or men charged with administration should be members of the board of review.