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stock of silver as a whole, otherwise available for subsidiary coinage, at all times being more than ample to meet the current needs for subsidiary coinage. In this connection the submission forming the basis of the decision of November 29, 1922, read, in part:

(* * * It further appears that the allocations of silver for subsidiary coinage under the act were made in part, to make up shortages at the individual coinage mints, rather than for the mint service as a whole, and in part to supply refined silver immediately available for coinage where the silver already on hand was unrefined. To this extent, therefore, it may be said that the allocations under the act were made in order to adjust the subsidiary coinage accounts of the several mints, rather than to meet a deficiency in the mint service as a whole."

Much of what is urged as mandatory as to purchases of silver upon allocation of silver dollars for subsidiary coinage is in connection with the provision in the act of 1918 that such allocation shall be regarded as a sale or resale for the purposes of the act, it being also provided in the act that upon every sale of bullion the Secretary of the Treasury shall immediately direct the Director of the Mint to purchase silver equal to a certain number of grains pure silver in respect of every stamped silver dollar melted or broken up and sold as bullion. It is a reasonable interpretation of the provision that an allocation of dollars for subsidiary coinage should be regarded as a sale was to give an authority for purchase, as to which authority there might otherwise be doubt, it being a transaction within the department and not clearly within the sales provision of the act, and thus the authority be permissive rather than madatory to make purchases on account of such transactions. At least, taking it in connection with the showing that there was at all times and exclusive of the allocations a sufficiency of silver in the subsidiary coin stock, the revoking of the allocations so as to permit restoration to the standard silver dollar stock the silver no longer needed in the subsidiary coin stock, to my mind, does not necessarily suggest conflict with that provision in section 3 which is clearly mandatory as to a true sale, such as a sale of bullion for commerical use.

Upon the submission of the matter by the Secretary of the Treasury I was, and now am, unable to bring myself to believe this provision mandatory so as to require that all allocations, however and for whatever purposes made, be treated as irrevocable sales.

Sincerely yours,

J. R. MCCARL, Comptroller General.

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COMMISSION OF GOLD AND SILVER INQUIRY.

TASKER L. ODDIE, Nevada, Chairman.
KEY PITTMAN, Nevada, Vice Chairman.

THOMAS STERLING, South Dakota.
FRANK R. GOODING, Idaho.

THOMAS J. WALSH, Montana.

H. N. LAWRIE, Assistant to Commission.
C. E. ALDEN, Secretary.

2. Wholesale price index-Purchasing power of gold in terms of wholesale com-
modities.

168

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3. Number of deep mines, placers, and dredges producing gold and sil-

ver and the principal producers of gold and silver in the United

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