Introduction to the exhibit "California's Gold Rush Revenues, Aristocrats of American Fiscal Philately: A Fiscal History," which shows examples of the five document types subject to California stamp taxes during 1857-1872: attorneys' licenses, bills of exchange, bills of lading for gold and silver, insurance policies and ships' passenger tickets.

1. California’s Gold Rush Revenues, Aristocrats of American Fiscal Philately: A Fiscal History
California’s Gold Rush set in motion another sort of rush — to grant statehood to this province of such immense mineral wealth. In September 1850, just thirty-three
months after James Marshall spied gold in the American River, Congress took the unprecedented step of granting California statehood even though it had never had a
Territorial government. Indeed, during its preceding Spanish, Mexican, and American Military and Republic periods, California had never had more than a minimal form
of government. It is not surprising that the early state legislatures, while quite willing to spend money, had little experience or expertise in raising it. From its inception, the
new state operated at a deficit. By 1857, cumulative expenditures had reached $7 million, but revenues totaled just $4 million. According to popular accounts, the State
was in danger of defaulting on its salary warrants. With this sort of motivation, the legislature was inspired to create a documentary stamp tax.
The Act of April 29, 1857, imposed a schedule of stamp taxes on attorneys’ licenses, bills of exchange, insurance policies, and passenger tickets, to take effect the
following July 1; and Attorney at Law, Exchange, Insurance, and Passenger stamps were created, the first adhesive revenue stamps in the United States, predating by
five years the U.S Civil War issues of 1862.
On April 26, 1858, the tax on bills of exchange was abruptly replaced by one on bills of lading for shipments of gold or silver, and Bill of Lading stamps were created
to pay it. Some three years later, the tax on bills of lading was declared unconstitutional by no less an authority than the U.S. Supreme Court, and was in turn replaced by
the original slate of Exchange taxes. After this the stamp taxes remained essentially unchanged until they were rescinded effective December 31, 1872.
The purpose of this exhibit is to illustrate these California stamp taxes via stamped documents (and a single off-document stamp) by showing as many tax rates as
possible, and within this framework, as many users and stamps as ten frames will allow.
• This is the first time all five types of documents — Attorney at Law, Bill of Lading, Exchange,
Insurance and Passenger — have been assembled in a single collection or exhibit.
The Stamps
To the delight of later generations of philatelists, specific stamps were created, not only for the five types of documents taxed, but for each tax rate within a given type.
To borrow a modern phrase, they were completely “user friendly”: they stated, not only the type of document on which they were to be used, and the tax, but also the basis
for the tax. For example, the Exchange stamp illustrated below has the wording “EXCHANGE SECOND Above $500 to $750 $1.40,” making it clear that it was intended
for use on a second bill of exchange for more than $500 but not more than $750. With such stamps, users had no need of a tax schedule; the schedule was reproduced
on the stamps themselves! While conceptually advanced, these early stamps were aesthetically unappealing, printed by crude woodcuts, a situation somewhat redeemed
by the fact that they are among the very few — and certainly the first — circular stamps in all of philately. In 1866 these “Circulars” were replaced by a series of engraved
general revenue stamps, in all necessary denominations from 4¢ to $175, elegantly engraved by Britton & Rey of San Francisco and printed in a rainbow of colors.
Examples have survived of more than 90% of the California revenue stamps originally issued, but virtually all are more or
less rare, and it seems safe to say that most philatelists, in 2015, are scarcely aware these stamps exist. It was not always so. A
hundred years ago listings
of California’s documentary
revenues (as well as the
classic issues of Alabama,
Louisiana, Nevada, and
Oregon) were readily
available, and they were
enthusiastically pursued by1857 Attorney, Exchange, Insurance, Passenger stamps; 1858 Bill of Lading stamp; 1866 general issue stamp

2. a wide range of collectors, not only in this country and especially in California, but in Europe as well. An extensive listing of all classic State revenues, compiled by New
York dealer Julius Adenaw, appeared in the American Journal of Philately as early as 1892–3, and was published separately the following year. Forbin’s widely circulated
catalogs of world revenues, first published in 1905, also included U.S. State documentary issues. However, the Scott U.S. Specialized catalog, which first appeared in
1923 and added Federal revenues in 1928, has always excluded even the classic state revenues (although their postal analogs, the local post issues of 1842-82, have
long been included). This virtually ensured the eventual obscurity of these fascinating stamps.
Significance of Users
Unlike postage stamps, California’s revenues were generally not sold to the populace by a network of post offices, but by the banks and companies generating the
documents to be stamped. By analogy with postal history, these banks and companies companies (“users”) were roughly analogous to post offices. Just as individuals
who mailed letters took them to post offices where postage stamps were affixed and canceled, so too citizens who executed, say, bills of exchange did so at offices
like those of Wells, Fargo & Co., where the requisite tax stamps were sold, affixed and (after April 1862) canceled. Moreover, the distinctive documents of the various
companies can be considered the fiscal analogs of postmarks. On a cover, the postmark shows where and when a stamp was used; on, say, a bill of exchange, it is the
bill itself that furnishes this information. Revenue cancels do not provide it. Cancellation of California stamps was not even required until April 1862, and thereafter was
required only to specify the date. Cancels were often omitted, incomplete, or indistinct. The only reliable way to tell how (or even if!) a California stamp was used is to
observe its intact document. Along with the rates and stamps, these users constitute the third fundamental aspect of California stamp usage. New users are sought as
avidly as postal historians search for previously unrecorded postmarks.
On Philatelic Importance
California is “only” a state, but then as now, its booming economy exceeded that of many countries. Moreover, events there during the period in question played a
critical role in the development of theAmerican West. Documents from this era have an inherent significance quite apart from any philatelic considerations, and are sought
by collectors of Western Americana. When one adds to this underlying general importance the fact that surviving documents of the late 1850s and early 1860s bearing
California stamps are the earliest known with adhesive revenues, not only from the United States (and with the exception of the relatively little-used 1856 issues of Spain
for its colonies Cuba and Puerto Rico, from the entire Western Hemisphere), it becomes clear that the philatelic importance of this field is of the highest order. Some one
hundred documents dating from the 1850s bearing California stamps have been recorded, bearing stamps from each of the five types, Attorney at Law, Bill of Lading,
Exchange, Insurance, and Passenger. These rare and precious survivors have aptly been dubbed “the Aristocrats of American Fiscal History.”
Difficulty of Acquisition
Two factors combine to make it
extremely difficulty to acquire a broad range
of material in this field. First, California’s
documentary tax rates were extraordinarily
detailed; the number of stamps produced
to pay them was vast; and the number of
users was large. As tabulated at left, nearly
200 rates were created, of which examples
have been recorded of 89; more than 450
stamps were created; and some 150 users
have been recorded. Second, surviving
stamped documents are inherently scarce.
Even though nearly 1.5 million stamps were
Stamps
Type Rates Rates Recorded Circular Rectangular Recorded Users
Attorney 1 1 3 1
Exchange I (1857–8) 22 15 100 20
Insurance I (1857–8) 22 1 13 2
Passenger 3 3 5 3 5
Bill of Lading (1858–61) 2 1 43 1
Insurance II (1858–61) 8 3 72 17
Exchange II (1861–6) 22 20 189 44
Insurance III (1861–72) 88 31 44 (65) 38
Exchange III (1866–72) 22 14 (65) 31
Totals 190 89 469 158

3. sold, and nearly that number of documents must have been generated, the recorded survivors number fewer than 800. Many thousands must have been destroyed in the
1906 San Francisco earthquake and fire.
These two factors combine to guarantee that representatives of the great majority of rates, stamps or users will be high-level rarities — existing in quantities of five or
fewer. [To illustrate, for the most common of the five taxed document types, bills of exchange, a longtime census now lists some 570 items, taxed at 49 different rates. The
most common of these, bills taxed at 8¢ or 20¢ per set, account for some 200 items; eight other rates count between 16 and 30 examples, accounting for another 170;
the remaining 200 or so bills are divided among 37 rates! For Insurance the situation is similar. Some 140 documents have been recorded, taxed at 34 different rates. For
16 rates no more than four examples have been recorded, and for five of these just one is known. For the other three document types, any example is a first class rarity:
only 33 stamped bills of lading have been recorded, eight attorney’s licenses, and six passenger tickets. For stamps and users a similar analysis applies.]
To obtain even a decent showing of rates — say, half of those recorded — would entail acquiring dozens for which at most a handful exist. This would probably be the
work of a decade or so; except for the most common bills of exchange, there is virtually no material in this field available in the marketplace.
• This exhibit includes 80 of the 89 recorded California stamp tax rates, nearly all stamps recorded on document, and the lion’s share of users.
• It includes virtually all of the key pieces of the field.
• It has been painstakingly assembled over nearly four decades, incorporating collections that were also decades in the making.
• It is an Ishikawa-like spead-eagling of a vast and important field: the usage of America’s first adhesive revenues, from the 1850s to the 1870s.
• Duplicating it or even materially improving on it would be impossible,
even with unlimited funds.
Attorney at Law
The $10 tax on attorneys’ licenses was so seldom applied that during the nine
years the Attorney at Law stamps were in use, a grand total of only 454 were sold.
Shown here is the Attorney’s License of Robert McGarvey, Stanislaus County,
October 13, 1857, stamped with $10 Attorney at Law blue. The handstamped script
initials “GWW” on the stamp are not a cancel, but
the initials of State Controller George W. Whitman,
required as a security measure. The blue Attorney
at Law stamp is so rare that its existence was not
known to philatelists until 1902. That summer Wells,
Fargo&Co.unceremoniouslydumpedonthestreets
of San Francisco dozens of boxes filled with a half-
century’s accumulation of letters and packages that
had proved undeliverable and unreturnable. From
this hoard George W. Hackett, a young Wells Fargo employee, retrieved the fabled
“Four Boxes of Trash” (Stern, 1957) which yielded hundreds of treasures of postal
and fiscal history, the most famous the cover bearing the unique strip of four of the
Wells Fargo “Garter Stamp.” This same find also yielded another item scarcely less
rare, but nowhere near as well known: an 1858 attorney’s license stamped with the

4. discovery copy of the California $10Attorney at Law in blue. News of this discovery evidently traveled rather slowly; as late as 1915 Forbin still listed this stamp only in red.
The blue Attorney at Law remains one of the rarest American revenues; seven copies are now known to exist. The copy shown here is only other one, besides Hackett’s
find, known on document (Mahler, 1993a).According to theAnnual Report of Controller Whitman for 1857, a mere tenAttorney at Law stamps were sold from July 1, 1857,
to December 15, 1857; the survival of one of these ten on an intact license certainly qualifies as at least a minor miracle. The color of the $10 Attorney at Law stamp was
changed early on from blue to red, probably in early 1859. Even in red, this stamp is a major rarity. Only three are known on intact documents.
Exchange I
A bill of exchange was an instrument essentially equivalent to a modern-day cashier’s check, by
which one party could send funds to another at a distant location, through a local banking house with
a branch or partner near the intended destination. For example, a California miner with gold dust to
send to his wife in the East could buy a bill of exchange in the desired amount from, say, a nearby
office of Wells, Fargo & Co., payable at the Wells Fargo head office in New York, and mail it home.
His wife would not have to take the bill to New York for payment; it functioned as a type of commercial
currency.Abill of exchange of Wells, Fargo & Co., properly endorsed, would be paid almost anywhere
in the U.S., and might change hands several more times before finally reaching their New York office.
Bills of exchange
were typically made in sets of two or more, essentially identical except for being designated
“First,” “Second,” “Third,” or similar terms, so made to allow for the possibility that one or
more might be lost in transit. By the late 1850s in California, usually only the First was
mailed to the destination, and the other bill(s) of the set held in reserve. Shown above
is a second of exchange of San Francisco bankers Tallant & Wilde, dated July 15, 1857,
drawn on Robb Hallert & Co. in New York for $200, stamped with Second Exchange 40¢
blue on white wove paper. The taxes had gone into effect July 1, 1857, but July 15 was
the first day stamps were available in San Francisco.
The tax on bills of exchange can be divided into four periods. The first lasted less than
ten months, ending abruptly on April 26, 1858, when the legislature replaced the tax on
bills of exchange with one on bills of lading, effective immediately. Any First Period bill is
rare; a census (Mahler, 1994), together with subsequent additions, accounts for just 72 First Period bills. 15 rates are represented (of a possible 22), and for ten of these,
no more than four examples have been recorded.
Exchange stamps exist that were separated using “cookie-cutter” style devices,
either circular, producing the so-called “die-cut” stamps, or star-shaped, resulting in
“star-cut” stamps. These command a premium, especially the latter. Only six star-cuts
have been recorded on intact bills; shown above is a beautiful engraved bill of D.O.
Mills & Co., Sacramento, bearing a 24-point star-cut blue 60¢ Second.
With the exception of Wells, Fargo & Co., which issued ten times as many bills
of exchange as any other establishment, the bills of the various banking houses and
merchants range from scarce to extremely rare, and are highly prized by collectors
of Western Americana. For example, shown at left is the only recorded stamped bill
of Reynolds Bros., pioneer bankers of Marysville.

5. Insurance I
The tax on insurance was originally defined to be half that on exchange. After less than ten months
the exchange tax was replaced by one on bills of lading, and the insurance tax was redefined to be
half that on bills of lading (see Insurance II below). During the 1857–8 First Period, a total of only 3321
Insurance stamps were sold, all in blue, spread over 20 denominations (no 4¢ or $100 stamps were ever
sold, only one $87.50, and four each of the $28 and $45; Mahler, 1997a, 2010). Any example is a first-
class rarity. None were known on document until a matched pair of policies surfaced in 2008 insuring
sewing machines of the Wheeler and Wilson Manufacturing Co. in San Francisco, each bearing a $1
blue Insurance (Mahler, 2008). One is illustrated at left.
Bill of Lading
The aforementioned Act of April 26, 1858, abruptly replaced the stamp tax on bills of exchange with
one on bills of lading for transportation of gold or silver out of the state. The tax was 30¢ for amounts to
$300, and for larger amounts, 0.2% on the entire amount. First, Second, Third, and Fourth Bill of Lading
stamps were produced in 11 denominations from 30¢ to $400.
The bill of lading tax was challenged and upheld in the San Francisco Court of Sessions in 1860,
then appealed to the U.S. Supreme Court, where on January 28, 1861, it was declared unconstitutional
on the grounds that it violated the stipulation that “No state shall, without the consent of Congress,
levy any imposts or duties on imports or exports ... .” This was the end of the tax on bills of lading. The
California Legislature implicitly rescinded it in its Act of May 9, 1861, and in its place reinstated the
original schedule of taxes on bills of exchange.
Any stamped bill of lading is a rare item; just 33 have been
recorded, all printed forms of the Pacific Mail Steamship Co.
Shown at right is a bill for shipment of $4,200 in gold bars
by William T. Coleman & Co. on the P.M.S.S.Co.’s Sonora in
June 1859, stamped with Bill of Lading Third $4 (x2) and 40¢.
Coleman is known to history as Chairman of the San Francisco

6. Vigilance Committee of 1855, which rose up against widespread criminal activity and corruption in the
justice system.
Insurance II
The original Insurance tax was tied to that on Exchange. When the latter was rescinded in 1858,
the tax on Insurance was not; it was merely reformulated, tied instead to the new Bill of Lading tax. For
policies with the usual one year term, the tax was half that on bills of lading, i.e., 15¢ on amounts to
$100, and for larger amounts, 0.1% on the entire amount. A new feature of the 1858 schedule is that
the tax on policies of duration less than a year was pro-rated: for policies of three to six months, the tax
was one fourth that on a one year policy; for six to nine months, one half; and for nine to twelve months,
three fourths. These short-term rates applied chiefly to marine insurance, which typically lasted only the
duration of a voyage.
To accommodate this rather unwieldy schedule, 36 large circular Insurance stamps were created,
printed in red, providing coverage in nine convenient amounts from $100 to $50,000, for each of the four
time brackets. Again, the stamps were completely user-friendly in that they stated, not only the tax, but
the time of the policy and the upper limit of its coverage. Illustrated at left is a policy of the Humboldt Fire
Insurance Co. of New York, executed in San Francisco in May 1859, amount $10,000 on merchandise,
for one year; the $10 tax was correctly paid with a 12 Mo./$10 stamp, the only recorded example on
document, and the highest-denomination large Insurance stamp recorded on document.
Exchange II
Bills of exchange were untaxed from April 1858 until the California tax on bills of lading was
declared unconstitutional and, effective May 1, 1861, replaced by the original slate of Exchange taxes.
This tax period lasted until 1866, and shows the Exchange tax in its fullest flowering: 230 examples have
been recorded, taxed at all but three of the 22 possible rates.Shown below is a Duplicate of exchange
of the Bank of California, San Francisco, amount $50,000, with the $90 rate for bills above $30,000 up
to $50,000 paid by stamps of $30, $20, $14, $10 (x2) and $6. The only higher brackets were $175 for
bills up to $100,000, and $200 for those over that amount; no
examples of either rate are known.
Exchange III
The Act of March 31, 1866, effective immediately, made
an important change in the letter of the law, necessitated by
the creation of the new series of general revenue stamps,

7. which replaced the old Exchange stamps. I consider this date as demarcating a new tax period. The previous taxes had applied not to each bill of a set, but to the entire
set, and accordingly, the denomination of an Exchange stamp represented, not the cost of the individual stamp, but that of the First, Second, and (if necessary) Third
Exchange stamps needed to stamp all bills of the set. For example, a set of bills for $50 was taxed at 8¢, and for 8¢ a user received the necessary 8c First, Second,
and Third stamps. The denominations of the new general revenue
stamps, however, represented their actual cost. Affixing the new
8¢ stamps to each of a set of two bills would cost 16¢. The new
law changed the rates so that the total tax on a set of two bills,
paid with the new stamps, would remain the same as before. It
did this by stipulating that if made in the customary sets of two,
each bill of a set was to be taxed at half the previous rate. This
necessitated stamps in new denominations half those of the old
Exchange stamps. For example, 4¢ stamps were created for use
on bills of $50, so the tax on a set of two would remain at 8¢.
Shown at right is an 1868 second of Tallant & Co., San
Francisco, amount $625, stamped with the beautiful 70¢ orange
rectangular and a U.S. 2¢ Bank Check blue imperforate. Before
the change in rates and stamps, a bill in this amount would have
required a $1.40 Second Exchange stamp.
Insurance III
The Act of May 9, 1861, replaced the Bill of Lading tax with the slate
of Exchange taxes originally set in 1857, and redefined the Insurance tax to be
half that on Exchange. A new set of Insurance stamps was created (the third
in four years), the same 22 small circular Insurance stamps earlier printed in
blue, now printed in red. These taxes continued in effect until 1872, with one
modification; the 1861 Act failed to pro-rate the Insurance taxes for short-
term policies, but this was remedied by the Act of April 10, 1862, after which
the rates remained unchanged until the repeal of all stamp taxes effective
December 31, 1872. In 1866 the Insurance stamps were replaced by the
rectangular general state revenue stamps. 65 Third Period usages have been
recorded. Illustrated at left is an 1869 policy renewal of the Hamburg-Bremen
Fire Insurance Co., California Agency, amount $20,000, tax $19, stamped
with $4 green (x3), $7 puce and U.S. 50¢ Original Process. This is the only
recorded example of the 1861–72 $19 rate, one of two recorded documents
bearing the $4 green, and one of three with the $7 puce.
The schedule of Insurance rates re-established in 1861 did not provide for
short-term policies, but theAct ofApril 10, 1862, stipulated that the 1861 rates
applied only to policies for nine months or more; and that those for six to nine

8. months, three to six months, and up to three months, respectively, would be
taxed at three quarters, one half, and one quarter of the 1861 rates. Unlike
the 1858–61 Second Period, when 9 Mo., 6 Mo., and 3 Mo. stamps were
created, this time no new stamps were issued for short-term rates, and until
now these rates have been virtually unknown to philatelists. Only ten such
documents have been recorded. Shown at right is a spectacular marine open
policy of the Union Insurance Co. covering 21 different voyages between San
Francisco and Mexican ports in the Gulf of California made between 1867
and 1870, with California tax paid for each voyage, the periods implicitly less
than three months and taxes 25% of the one-year rates, amounts $100 to
$4,000, taxed at nine different rates: 2½¢, 10¢, 12½¢, 17½¢, 25¢, 37½¢,
50¢, 75¢ and $1, all but the last recorded on no other policies, paid by a total
of 35 state stamps. The 12½¢, 17½¢ and 37½¢ rates were paid with 15¢,
20¢ and 40¢ stamps, as exact payment was impossible; the single 2½¢ tax
was combined with that for another voyage made the same day. The fifth
stamp from the bottom is a rouletted 10¢ used November 22, 1869, one of
only seven recorded roulettes on document, and the earliest recorded.
Passenger Ticket
The original schedule of 1857 imposed a tax on any purchase of passage
out of the State on any vessel, the stamp(s) to be placed on the “receipt …
contract, certificate or memorandum” of sale. The rates were $6 for first class
passage, $4 for second class, and $2 for steerage, and Passenger stamps
were created in these three denominations. The stamps remained in use for
nearly a decade, and some 118,000 were sold, nearly all to the Pacific Mail
Steamship Co. (Kenyon, 1920), but today any Passenger stamp is a first
class rarity, as virtually all stamped tickets were surrendered to the shipping
line, and systematically destroyed.
Shown at left is a Passenger $6 1st
Class stamp in blue on blue horizontally
laid paper. For over a century, philatelists
were unaware of any Passenger stamps
in blue. Smith (1903) stated “Neither the
Attorney-at-Law nor [any] of the three
Passenger Ticket stamps have yet to be
found in blue, but there can be little doubt
that they were printed in that color.” As
described above, unbeknownst to Smith,

9. a blue Attorney stamp had in fact been discovered in 1902, but blue
Passenger stamps remained elusive. In his monumental state revenue
catalog Cabot (1940) did not list them, nor did Hubbard’s 1960 update
of Cabot. Thus it came as a colossal surprise that the 1991 auction of
the Elbert Hubbard California revenues contained two $6 Passenger
stamps in blue. They were described in the auction catalog as unlisted
color errors, and their significance was not realized immediately (Mahler,
1993b). One is illustrated at left.
For years, Western collectors believed no intact tickets bearing
California Passenger stamps had survived. However, the holdings of
the legendary, reclusive Morton Dean Joyce of New York, dispersed in
1990, contained two such treasures. One is shown here, a ticket of the
Linea de Paquetes for Second Class passage on the Goleta Clipper
“Giulietta,” San Francisco to Guatemala, October 19, 1859, stamped
with Passenger $4 2d Class on thin bluish paper.
References
Cabot, George. Priced Catalogue of the State and City Revenue and Tax Stamps of the United States. Weehawken NJ, 1940.
Hubbard, E.S.A. State Revenue Catalog. Portland ME: Severn-Wylie-Jewett, 1960.
Kenyon, Brewster G. Documentary State Revenue Stamps of the United States. Long Beach CA, 1920.
Mahler, Michael. California State Revenues. A Second Blue Attorney Stamp Surfaces on Document. The American Revenuer, 1993a October; 47:238-239.
Mahler, Michael. California State Revenues. Yes, Virginia, There is a Blue Passenger Stamp, The American Revenuer, 1993b November-December; 47:274-5.
Mahler, Michael. A Preliminary Census of Bills of Exchange Bearing California Revenue Stamps, State Revenue Newsletter 1994 March-April:6-15.
Mahler, Michael. California Stamp Taxes, First Period July 1, 1857, to April 26, 1858. Quantities of Exchange and Insurance Stamps Issued and Sold. The American
Revenuer 1997 September; 51:190–204.
Mahler, Michael. The Wheeler and Wilson Find: California Blue Insurance Stamps Surface on Document. TheAmerican Revenuer 2008 November-December; 62:152–
163.
Smith, Ed. California State Tax Stamp. Mekeel’s Weekly Stamp News, 1903 March 21:129-130.
Stern, D. K. Four Boxes of Trash. Westways, 1957 May:16-17.
Wrisley, Dave. The State Revenue Catalog. State Revenue Society, 2013.