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“And that the right in the said sum of 20,000 francs, corresponding to the premiums to be paid, combined with the aleatory value of the risk assured, formed a part of the assets of the insured, who could dispose, and did dispose of it, and that, the legatee not having accepted the bequest, it devolved upon his heirs, who found it in his estate;

“And that consequently the said sum ought to have been included by the defendants in the return to be made of the succession, and was liable to the succession duty;

“And that the decree brought into Court, having decided in the contrary, has violated the above mentioned provisions of the law;

“Quashes it.” (7 February 1872.)

So far as jurisprudence goes, this decision of the Court of Cassation is quite unexceptionable, for it has laid down the only principles conformable to the present state of French legislation ; but we do not mean to say that the law ought not to be altered. We know life insurance deserves to be encouraged by the government, and in France needs such encouragement, and we should have no objection to any legislative amendment that would either make a general exemption from the succession duty in favour of life insurance policies, or, at least, exempt from it all policies, under a certain sum, made for the benefit of one's wife, husband, or children.

Note on Mr. Woolhouse's paper "On the Philosophy of Statistics." MR. D. Carment has pointed out to us a close verbal agreement between a passage in Mr. Woolhouse's paper “ On the Philosophy of Statistics” (see p. 37 of this volume), and Mr. O. G. Downes's translation of M. Quetelet’s Letters on the Theory of Probabilities. It appears, indeed, that certain portions of pages 40, 41, and 42, have been transcribed from the latter work with but little alteration. Mr. Woolhouse states, with reference to this, that "the object

sought to be accomplished in the paper is that of embodying a “full and comprehensive view of what has been done on a subject “ not generally understood, and at the same time of making the “ discussion as complete as possible by giving much original and

important matter not to be found elsewhere in form or substance." Considering the wide range of the subject, and its intimate connection with an important branch of mathematical science, entire

life insurance policies. By the advocates of that doctrine, the right in the sum assured was thought never to have vested in the person effecting the policy, and the assurance monies were said to be transferred directly, i. e., omisso medio, from the assurer to the party entitled to receive the sum assured ; and that sum, accordingly, would not be liable to succession duty.

To us that doctrine always appeared quite untenable; we could not regard the assurance monies as standing on a different footing from

any other portion of the assets a person may be possessed of, and though we were not actually confident of the ultimate success of our opinion, we set forth, in a book written in 1867, the reasons that made us believe that the time would arrive when the decisions of so many Courts, conformable to the doctrine of most people versed either in the law or the practice of life insurance, would be over-ruled some day by the Supreme Court. We triumphed, at last, beyond our most sanguine expectations : the outlawry of Life insurance is now no more; it will henceforward be subject, as any other contract, to the operation of the written law. It may be true that the interest of the public exchequer, which was a loser in the positions maintained by our adversaries, contributed a little in turning the scale of victory; but, be that as it may, the construction of life insurance is now restored to sounder principles. Contrary to the doctrine of the Courts of Caen, Lyon, Colmar, Rouen, Paris, it has been held by the Court of Cassation (Chambre Civile) that the assurance monies form part of the estate of the deceased, like any other description of property. It was an action brought by the Stamp Officers (L'Enregistrement v. Krieg) for the payment of an ad valorem duty upon a sum of 20,000 francs insured by one M. Krieg for the benefit of his legal representatives, and made payable within four months after his death. The policy had been disposed of by M. Krieg in his will, but the legatee not having accepted it, the legal representative of the deceased became entitled to its benefit. The tribunal of Saverne decided for the defendant (21st May 1869), upon the ground that the benefit of a life assurance policy was not deemed to confer a succession ; but its decision has been annulled by the above mentioned judgment of the Court of Cassation, which is to the following effect :

“Whereas it appeared that Krieg insured upon his life at the Caisse Générale des Familles, in consideration of an annual premium of 420 francs, the sum of 20,000 francs, made payable to his representatives within four months after his death;

“And that the right in the said sum of 20,000 francs, corresponding to the premiums to be paid, combined with the aleatory value of the risk assured, formed a part of the assets of the insured, who could dispose, and did dispose of it, and that, the legatee not having accepted the bequest, it devolved upon his heirs, who found it in his estate;

"And that consequently the said sum ought to have been included by the defendants in the return to be made of the succession, and was liable to the succession duty;

“And that the decree brought into Court, having decided in the contrary, has violated the above mentioned provisions of the law;

Quashes it.” (7 February 1872.)

So far as jurisprudence goes, this decision of the Court of Cassation is quite unexceptionable, for it has laid down the only principles conformable to the present state of French legislation; but we do not mean to say

that the law ought not to be altered. We know life insurance deserves to be encouraged by the government, and in France needs such encouragement, and we should have no objection to any legislative amendment that would either make a general exemption from the succession duty in favour of life insurance policies, or, at least, exempt from it all policies, under a certain sum, made for the benefit of one's wife, husband, or children.

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Note on Mr. Woolhouse's paper On the Philosophy of Statistics." MR. D. Carment has pointed out to us a close verbal agreement between a passage in Mr. Woolhouse's paper “On the Philosophy of Statistics” (see p. 37 of this volume), and Mr. O. G. Downes's translation of M. Quetelet's Letters on the Theory of Probabilities. It appears, indeed, that certain portions of pages 40, 41, and 42, have been transcribed from the latter work with but little alteration. Mr. Woolhouse states, with reference to this, that “the object

sought to be accomplished in the paper is that of embodying a “ full and comprehensive view of what has been done on a subject “not generally understood, and at the same time of making the “ discussion as complete as possible by giving much original and

important matter not to be found elsewhere in form or substance.” Considering the wide range of the subject, and its intimate connection with an important branch of mathematical science, entire

originality is of course not to be expected in a full account of it; and
the fact of Mr. Woolhouse having, in his general introductory state-
ments, borrowed more or less from M. Quetelet's dissertations, simply
amounts to an admission that the latter had expressed himself so
happily with regard to the matters the former had under discussion,
that he did not think he could improve on the phraseology.
It should also be borne in mind, that the letters of M. Quetelet
are not to be regarded exclusively as an original source of infor-
mation, but chiefly as an intelligible and familiar exposition of the
scientific results of his predecessors.-ED, J. I. A.

-U

u

+W.

Correction of an Error in Milne's Treatise on Annuities and

Assurances.
WE are indebted to Mr. Henry Hoskins, of 28 Notting Hill Square,
for the following: -

In a footnote on pp. 254-256, Mr. Milne has investigated the
value of a joint-life annuity on the hypothesis of equal decrements
throughout life, but for the latter part of the investigation, com-
mencing at the 5th line of the footnote on p. 255, should be
substituted:
Thus it appears that the total value of the annuity is

2u

(m+m')
1.

(m + 1)24m+1-
U
1+

mm

mm' (1-u)

U which expression by writing

for W, and observing

(1-u)
u(l— um)
that U=

be transformed to
7(1-u)
1
2u

2u

i +
1-u ma (1-0)
1
2

2
1+

:(1+3) ***-{ +1-(m + m') } +

(1+3)*

(1+)-1
Cor. 1. When the annuity is payable at the same v equal
intervals in the year at which the interest is convertible, v being
=, and u=1, the formula last obtained becomes

mum+1

1-U

, may

[blocks in formation]

m

3)-1

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Cor. 2. When the expectation of the senior of the two lives is s years and that of the junior j years, m=2vs, m'=2vj, and the formula becomes

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V being the value of an annuity certain of one pound for the term

of 2s years.

Cor. 3. When the interest and the annuity are each payable but once a year, v=1, and the value of the annuity is

(1

1 1

+

(s+i)

The Life Assurance Companies Acts, 1871 and 1872.

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An Act to amend the Life Assurance Companies Act, 1870.

[24th July 1871.] WHEREAS by section three of the Life Assurance 33 & 34 Vict.

Companies Act, 1870, a sum of money is required in c. 61. certain cases to be deposited with the Accountant General of the Court of Chancery, to be invested and returned by him in manner therein directed, and it is expedient to make further provision in respect of the deposit, investment, and return of such sum:

Be it therefore enacted by the Queen's most Excellent Majesty, by and with the advice and consent of the Lords Spiritual and Temporal, and Commons, in this present Parliament assembled, and by the authority of the same, as follows:

1. Every sum required by the Life Assurance Com- Payment into panies Act, 1870, to be deposited with the Accountant Orders as to General of the Court of Chancery shall be paid into the sums.de Court of Chancery, and orders with respect to the pay- 53 & 34 Vict. ment of such money into and out of court, and the invest. C. 61, s. 3. ment and return thereof, and the payment of the dividends and interest thereof, may be from time to time made, altered, and revoked by the like authority and in the like manner as orders with respect to the payment into and

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