SOME RESERVATIONS MADE BY COMMISSIONER COSTIGAN RESPECTING THE COMMISSION’S RE- PORT ON THE COSTS OF PRODUCTION OF SUGAR BEETS The accompanying report on sugar beets fails to make note of cer- .ain limitations which affect the commission’s findings. Care should be exercised in considering the data presented and particularly in oasing conclusions on such data. So far as the undersigned is con- cerned, such data are submitted subject to the following qualifications and reservations: Practically no statistical or accounting data can be pronounced absolutely accurate. However, the information which is available in industrial accounting is especially dependable because of the great care and the large sums of money devoted to such accounting in the regular course of efficient modern business. Farm accounting is at present more liable than industrial accounting to uncertainties and inaccuracies, partly for the reason that the data secured rest largely upon memory rather than upon reliable records. Nor does it suffice to suggest that error must always be expected, since it is unfair to conclude that some margin of error in industrial accounting may be used to excuse any margin of error, however wide, in farm accounting. Moreover, with particular reference to the present investigation, the business of the average sugar-beet farm consists in effect of a number of farm enterprises. It 1s a task of extraordi- nary difficulty to determine accurately costs of and returns from a single one of these enterprises. This is so because of the comple- mentary character of the various farm costs and farm returns, be- cause they represent a combination of business and family affairs, and finally, because so large a part of the total consists of imputed costs necessitating a large number of appraisements. As stated, the commission in the sugar-beet investigation adopted the ‘““enterprise survey.” This method of accounting has been gen- erally accepted by farm-management experts in the United States, and the details of its application have been described. For farm- management studies and for comparing conditions in different areas such surveys have value. It is to be borne in mind, however, that their use in determining profits, losses, and absolute costs is open to serious objections, not merely because of the inaccuracies referred to, but also because of the principles of accounting implied in such surveys. The farm accountant either does not accept, or is unable to insist upon, certain principles developed in industrial accounting. This becomes evident when the differences in methods of treating land values and interenterprise profits are considered. For example, the industrial cost accountant ordinarily questions the use in computing capital charges of data which reflect the present estimated values of farm lands in place of the costs of such lands