T 7ALUATI0N practice in the United States has been a controT versial issue for many years. Courts and commissions do not agree on the fundamental principles of valuation. The purpose of this paper is to discuss the various methods of valuation and the trends in practice in recent years. Today, practically every state has a regulatory commission with rate-making powers applicable to public utilities. Such a commission is usually known as a Public Service Commission, Railroad Commission, or by some similar title. The commission generally has authority to fix reasonable rates for public-utility services. Such rates can usually be established only after an investigation and public hearing, held upon the initiative of the consumers, the utility or the commission itself. After the hearing, in the light of the evidence presented and of its own investigation, the commission reaches a conclusion as to the value of the property, establishes the reasonable rate of return which the utility is entitled to receive and determines the necessary gross revenue. The commission then issues a schedule of rates designed to furnish such a gross revenue. Either the consumers or the utility may request a rehearing before the regulatory commission, should they desire to challenge the commission's findings. Failing to receive satisfaction after a review of the points at issue, either party may then take the case to the state court on points of law. The case may also be brought before the federal court by the utility, on the ground that the rates as fixed by the regulatory commission are confiscatory and are therefore in violation of the Fourteenth Amendment to the Constitution of the United States. When the case has once reached the federal courts