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== Rationale ==
== Rationale ==
=== Moral panic and homophobia ===
=== Moral panic and homophobia ===
During the 19th century in the United States, calls for a bachelor tax were frequently driven by a [[moral panic]],<ref name="france"/> and the bachelor tax was viewed as a way to reform social ills.<ref name="south_africa"/><ref name="new_jersey"/> Either because individuals believed that bachelors had a higher rate of delinquency, or because they believed that many bachelors were [[confirmed bachelor|closeted homosexuals]].<ref>{{cite news|title=Reviewed Work: Sex and the Eighteenth-Century Man: Massachusetts and the History of Sexuality in America by Thomas Foster|author=Hemphill, C. Dallett|journal=Journal of the History of Sexuality|volume=20|issue=3|date=September 2011|pages=630–634|quote=showing more change over time in attitudes towards unmarried men. While Foster refers to newspaper jests about a bachelor tax, for example, McCurdy tells their actual story. Foster does intervene in the acts versus identities debate over homosexuality}}</ref><ref>{{cite news|author=Blount, Jackie M.|title=Spinsters, Bachelors, and Other Gender Transgressors in School Employment, 1850-1990|journal=Review of Educational Research|volume=70|issue=1|year=2000|pages=83–101|doi=10.2307/1170595|jstor=1170595|url=https://doi.org/10.2307/1170595|quote="A bachelor is consider 'odd' or 'peculiar,' vain, selfish, and even a delinquent member of society" At the time, the terms "odd" and "peculiar" (especially when wrapped by quotation marks) were sometimes used as code for "homosexual" in polite conversation.}}</ref>
During the 19th century in the United States, calls for a bachelor tax were frequently driven by a [[moral panic]],<ref name="france"/> and the bachelor tax was viewed as a way to reform social ills.<ref name="south_africa"/><ref name="new_jersey"/> Either because individuals believed that bachelors had a higher rate of delinquency, or because they believed that many bachelors were [[confirmed bachelor|closeted homosexuals]].<ref>{{cite news|title=Reviewed Work: Sex and the Eighteenth-Century Man: Massachusetts and the History of Sexuality in America by Thomas Foster|author=Hemphill, C. Dallett|journal=Journal of the History of Sexuality|volume=20|issue=3|date=September 2011|pages=630–634|quote=showing more change over time in attitudes towards unmarried men. While Foster refers to newspaper jests about a bachelor tax, for example, McCurdy tells their actual story. Foster does intervene in the acts versus identities debate over homosexuality}}</ref><ref>{{cite journal|author=Blount, Jackie M.|title=Spinsters, Bachelors, and Other Gender Transgressors in School Employment, 1850-1990|journal=Review of Educational Research|volume=70|issue=1|year=2000|pages=83–101|doi=10.2307/1170595|jstor=1170595|url=https://doi.org/10.2307/1170595|quote="A bachelor is consider 'odd' or 'peculiar,' vain, selfish, and even a delinquent member of society" At the time, the terms "odd" and "peculiar" (especially when wrapped by quotation marks) were sometimes used as code for "homosexual" in polite conversation.}}</ref>


=== Racial-based eugenics ===
=== Racial-based eugenics ===

Revision as of 18:12, 8 June 2022

Late 19th century illustration and perspective on the bachelor tax.

A bachelor tax is a punitive tax imposed on unmarried men. In the modern era, many countries do vary tax rates by marital status, so current references to bachelor taxes are typically implicit rather than explicit; and given the state of tax law is very complicated, as tax accountancy concepts like income splitting can come into play.[1][2]

Such explicit measures historically would be instituted as part of a moral panic due to the important status given to marriage at various times and places (as in Ancient Rome, or in various U.S. state legislatures during the early 20th century).[3][4][5][6] Frequently, this would be attached to racial (e.g., as part of Apartheid policies)[5] or nationalistic reasons (as in Fascist Italy or Nazi Germany).[7][8]

More recently, bachelor taxes were viewed as part of a general tax on childlessness, which were used frequently by member states of the Warsaw Pact.[9][10][11]

Timeline

Location Date(s) Passed Comment
Ancient Rome 9 AD Yes
Main article: Lex Papia Poppaea § Promotion of Marriage
See also: Aes uxorium

The Lex Papia Poppaea was introduced by emperor Augustus to encourage marriage. In particular, penalties were imposed on those who were celibate, with an exception granted to Vestal Virgins (Ulp. Frag. xvii.1). The law also imposed penalties on married persons who had no children (qui liberos non habent, Gaius, ii.111) from the age of twenty-five to sixty in a man, and from the age of twenty to fifty in a woman. (Tacit. Ann. xv.19).[3]

Nevers, France 1223 Yes Charged a yearly tithe of five solidi to any bachelor as part of a moral panic.[12][13]
Ottoman Empire 15th century Yes
Main article: Resm-i mücerred

Resm-i mücerred was a bachelor tax instituted in the Ottoman Empire in conjunction with the resm-i çift and the resm-i bennâk.[14] Those who fell under the tax were more likely to migrate to other areas. Migrant mücerred were more likely to make their way to a growing town.[15]

England 1695 Yes
Main article: Marriage Duty Act 1695

The English parliament passed the Marriage Duty Act 1695, also known as the Registration Tax, which imposed a tax on births, marriages, burials, childless widowers, and bachelors over the age of 25. It was primarily used as a revenue raising mechanism for war on France and as a means of ensuring that proper records were kept by Anglican church officials. The tax was found ineffective and abolished by 1706.[16][17][13][3]

England 1798 Yes An income tax was passed particularly discriminating against bachelors [17][13]
United States, Missouri 1821 Yes Missouri applied a $1 tax on all unmarried men.[18] By the following year, it was replaced by a poll tax.[19]
United States, New York 1825 No A bill was proposed in the New York legislature comparing bachelors with dogs, aiming to replace the then current tax on dogs with one on bachelors instead.[3]
United States, Connecticut 1857 No The Connecticut legislature repealed a motion to implement a bachelor tax in the state, under the argument that different methods of taxation already taxed bachelors more heavily.[3]
United States, Michigan 1837, 1848, 1849, 1850, 1897, 1901, 1911, 1919, 1935 No Michigan had made repeated attempts to instantiate a bachelor tax. In 1837, state senator Edward D. Ellis attempted to pass such a bill, but the measure failed. In 1848, a petition made it to a House committee, but did not reach the floor. In 1849, another proposal was made in a House committee that did not reach the floor. Again in 1850, another petition reached the House, but did not find a sponsor. During the Civil War it was proposed again, this time as a revenue measure as opposed to a public welfare measure, but again failed to reach the floor. It was then repeatedly brought up in 1897, 1901, 1911, 1919, with the first resulting in counter proposals for a similar tax to be applied to women who reject marriage proposals and the final resulting in arguments that bachelors had a statistically higher rate of delinquency as opposed to other groups. The final proposed bill that also made the floor of the Michigan Congress was in 1935 before it too failed due to economic considerations of the time.[5]
United States, Wyoming 1890 No Briefly considered a $2.50 bachelor tax in 1890, but the motion was tabled.[20]
United States, New Jersey 1898-02-12 No Assemblyman Waller of the New Jersey State Legislature proposed a bachelor tax as a sumptuary tax; however, the bill was not passed.[6]
Argentina 1900 (est.) Yes A bachelor tax existed in Argentina around 1900. Men who could prove that they had asked a woman to marry them and had been rebuffed were exempt from the tax. In 1900, this gave rise to the phenomenon of "professional lady rejectors", women who for a fee would swear to the authorities that a man had proposed to them and they had refused.[21][3]
United States, Delaware 1907 No Started as a joke before generating much discussion and ultimately being defeated.[3]
United States, Georgia 1911 No One assemblyman proposed a $50 yearly tax on bachelors, proposing that the funds should go to schools.[3]
United States, Minnesota 1911 No Proposed a $5 yearly levy on bachelors.[3]
France 1913 No Proposed not only a large tax on bachelors, but also "spinsters."[3]
Reichenburg, Germany 1915 Yes As part of a progressive taxation measure.[3]
South Africa 1919 Yes Imposed a bachelor tax for racial reasons in order to match the white population growth with the black one.[5]
United States, Wisconsin 1921 No Generated frequent moral debate at the time.[3]
United States, Montana 1921 Yes Applied a $3 tax on all bachelors in the state.[22] One of them, William Atzinger, refused to pay on sex discrimination grounds.[23] On January 11, 1922, the state supreme court struck down the “bachelor tax” and another poll tax applicable only to men.[24][25] However, it was done on the grounds that the Montanan constitution of 1889 did not grant the legislature the power to tax individual persons; and attempts to define it as a policing measure for matters of public health as opposed to a revenue measure were found invalid (and the decision did not reference Atzinger's arguments against the tax on grounds of sex discrimination).[22]
Germany, Repelen 1923 Yes Passed a bachelor tax of 2000 marks per month. However, this law was quickly overturned by federal authorities.[26]
Italy 1927 Yes Levied in Italy from 1927 until the fall of Mussolini in 1943[27] as part of a race-based pronatalist policy. By 1936, Italian bachelors paid nearly double their normal income tax rate.[28][29][3]
Spain 1928 Yes Following in the footsteps of Italy, Spain also passed a bachelor tax,[30] only with very few exceptions, including priests as well.[31]
Germany 1934 Yes
Main article: Ehestandshilfe

Following in the footsteps of Italy and Spain, but mainly for Nazi party "family values." In particular, it was meant as part of Hitler's "three Ks" policy (Kirche, Küche, Kinder or Church, Kitchen, Children) to get women "back into the home."[3][32][33]

United States, California 1934 No As a response to the low 1933 birth rate in California, minister of Finance Roland Vandegrift proposed a $5 to $25 bachelor tax, but the measure did not succeed due to economic considerations of the time.[34]
France 1939 No Meant as a proposal to match similar proposals in Fascist Italy and Nazi Germany.[3]
Soviet Union 1941 Yes A childlessness tax was enforced in the USSR from 1941 to 1992; it was applied to childless men from 25 to 50 years of age and to childless women from 20 to 45 years of age. The tax was income based, taking 6% of the childless person's wages.[35]
Bulgaria 1925, 1943, 1968 Yes Measures to try to introduce a bachelor tax in Bulgaria first began in 1917, where it often took on a pro-eugenic character and part of discussion amongst Bulgarian Fascist party officials.[36] It was formally proposed by 1925,[3] only formally introduced in 1943, but passed only in 1968 only after applying it to both sexes.[37]
Poland 1946 Yes Introduced Bykowe, which was a tax on childlessness that included a tax on those unmarried above 21 years from January 1, 1946 to November 29, 1956. It was later extended to those over 25 years of age until January 1, 1973 when it was repealed.[11]
Turkey 1949 Yes Suggested and passed as a wealth transfer between bachelors to families.[38]
Romania 1986 Yes Some time after the population increase from the decreţei 770 generation, a celibacy tax was instituted. The law continued to be enforced until the Romanian Revolution of 1989.[39][9]
Italy, Vastiogirardi 1999 No The mayor of Vastogirardi, Italy proposed to reinstitute a bachelor tax locally.[40]

Rationale

Moral panic and homophobia

During the 19th century in the United States, calls for a bachelor tax were frequently driven by a moral panic,[12] and the bachelor tax was viewed as a way to reform social ills.[5][6] Either because individuals believed that bachelors had a higher rate of delinquency, or because they believed that many bachelors were closeted homosexuals.[41][42]

Racial-based eugenics

The bachelor tax has a long history of being used for race-based pronatalism policies. In the early 20th century, this morphed into a general discussion of "race suicide",[3][43] and consequently there was much literature supporting racial-based pronatalist policies, typically in the field of eugenics.[44][36] After such measures were passed in South Africa in an attempt to align white birth rates with black rates,[5] it passed to Benito Mussolini, who explicitly called for it to spread Italian progeny in a speech on May 26, 1927:

Let us be quite clear: what are 40 million Italians compared to 90 million Germans and 200 million Slavs? What are 40 million Italians compared to 40 million Frenchmen, plus 90 million inhabitants of their colonies, or 46 million Englishmen plus 450 million people who live in their colonies?[29]

Thereafter, the idea of the bachelor tax was passed over to Fascist Spain, Nazi Germany, was discussed in Bulgarian Fascist circles, and became a staple of Fascist propaganda in general.[36][45][3]

Communist family planning

Main article: Tax on childlessness

Many Warsaw Pact countries instituted some form of a bachelor tax, such as the Soviet Union,[35] Poland,[11] Romania,[9][39] and Bulgaria.[37] Typically, it formed a part of Communist natalist policies, the taxes on childlessness, and family planning policies that were instituted in Communist countries[10] at around the same time in order to increase falling fertility rates.[46][47]

Analysis and present day

Today, bachelor taxes have for the most part been superseded by the inclusion of marital status in the tax code.[48] The first distinction in marital status as part of an income tax happened in the U.S. by 1930 after Poe v. Seaborn, where "income-splitting" was allowed in community property states. Therefore, until 1948, tax rates amongst married and bachelors differed based on one's state of residence. This disparity lead to joint-filing status being allowed by U.S. Federal tax law in 1948 to attempt to harmonize the tax code between community property and common law states.[49] After the war, joint filing and marital status began to be incorporated instead of explicit bachelor taxes into the U.S. tax system and soon spread to other tax systems around the world.[50][2]

According to a 2010 study in the Journal of the Society for the Anthropology of Europe, the utility of the tax has been mixed, as analysis of past historical episodes have questioned the reliability of the tax to results in pronatalist outcomes. In Fascist Italy, it was found to be ineffective, as birth and marriage rates actually decreased.[51] In the Soviet Union, the effect on the fertility rate of the policy was likewise inconclusive; and it was also found to be fairly regressive, as it tended to hit rural, poorer bachelors hardest.[37] However, modern day implementations of taxation based on marital status in the U.S. has found a positive correlation with marriage rate.[52]

See also

References

General references

  • Long, George (1875). "Lex Papia Poppaea". A Dictionary of Greek and Roman Antiquities: 691–692.
  • Treggiari, S. (1993). Roman Marriage : Iusti Coniuges from the Time of Cicero to the Time of Ulpian. Oxford and New York: Clarendon Press..

Inline citations

  1. ^ BIRD, RICHARD M. (1978). "ON THE IMPORTANCE OF TAX DETAILS: JOINT VS. INDIVIDUAL FILING". National Tax Journal. Vol. 31, no. 2. National Tax Association. pp. 203–04. JSTOR 41863114.
  2. ^ a b Allègre, G., Périvier, H. & Pucci, M. (2021-03-20). "Taxation of Couples and Marital Status – Simulation of Three Reforms of the Marital Quotient in France". Economie et Statistique / Economics and Statistics. pp. 526–527.{{cite news}}: CS1 maint: multiple names: authors list (link)
  3. ^ a b c d e f g h i j k l m n o p q r Kornhauser, Marjorie E. (July 12, 2012). "Taxing Bachelors in America: 1895-1939". Tulane Public Law Research Paper No. 17-7. doi:10.2139/ssrn.2934318.
  4. ^ Aulus Gellius (1795). The Attic Nights. Printed for J. Johnson ... Retrieved 18 March 2016.
  5. ^ a b c d e f Barnett, Le Roy (2013, Winter). "The Attempts to Tax Bachelors in Michigan". Historical Society of Michigan, pp. 18-19.
  6. ^ a b c "Jersey's Bachelor's Tax." New York Times. 13 February 1898.
  7. ^ J. Pollard, The Fascist Experience in Italy, London, 1998, pp. 78-9.
  8. ^ "Mussolini Imposes Tax on Bachelors." The Evening Independence. 10 December 1926.
  9. ^ a b c "Romanian Pro-Natalism by Max Rudert on Prezi". prezi.com. Retrieved 2014-09-14.
  10. ^ a b "Tax on childlessness, which existed in the Soviet Union, proposed to be restored" ("Налог на бездетность, существовавший в СССР, предлагают восстановить") http://www.finiz.ru/cfin/tmpl-art/id_art-1054929 (accessed January 3, 2010.)
  11. ^ a b c Art. 20 Dekretu z dnia 26 października 1950 r. o podatku dochodowym, j.t. Dz.U. nr 7 z 1957 r., poz. 26.
  12. ^ a b Hulme, Roland (July 2017). "Ye old taxes". Vol. 21, no. 5. Renaissance Magazine. Before the days of the eligible bachelor, unmarried men were seen as rather unseemly.
  13. ^ a b c Hugh Chrisholm (1910). The Encyclopædia Britannica: A Dictionary of Arts, Sciences, Literature and General Information. Vol. 3. University Press. p. 132. with its late and countess of Nevers, to Auxerre in 1223, an annual tax of five rare variant baccalaris—cf. Ital. baccalare—through 0. Fr. solidi is imposed on any man qui non habet uxorem et est bachebacheler)...Instances of this are the is still involved in a certain amount of obscurity. The derivation act (6 and 7 Will. III.) passed in 1695; the tax on servants, from Welsh bach, little, is mentioned as "possible " by Skeat 1785; and the income tax, 1798. (Etymological Dictionary), but is definitely discarded by the New
  14. ^ Coşgel, Metin M. (2005). "Efficiency and Continuity in Public Finance: The Ottoman System of Taxation" (PDF). Int. J. Middle East Stud. 37 (4): 567–586. doi:10.1017/s0020743805052207. S2CID 6972997.
  15. ^ Gumuscu, Osman (2004). "Internal migrations in sixteenth century Anatolia". Journal of Historical Geography. 30 (2): 231–248. doi:10.1016/j.jhg.2003.08.021.
  16. ^ Gibson, Jeremy. The Hearth Tax, Other Later Stuart Tax Lists, and the Association Oath Rolls: FFHS, 1996.
  17. ^ a b Charles Arnold-Baker (2001). The Companion to British History. Routledge.
  18. ^ "A copy of Assessor’s General alphabetical lists of Taxable property in Boone county Mo for the year 1821". Boone County, O. Harris Sheriff & Collector. Received auditors office, August 2nd, 1821.
  19. ^ Bill Eddleman (2021-07-22). "Missouri Bicentennial Minutes: The Bachelor Tax". KRCU Public Radio. Retrieved 2022-03-07.
  20. ^ Roddam, Rick (July 9, 2020). "Wyoming's First Tax Controversy: The Proposed Bachelor Tax of 1890". 101.9 KING FM. Retrieved 2021-07-20.
  21. ^ How taxes turned margarine pink, made ships sink, and more strange results
  22. ^ a b STATE EX REL. PIERCE ET AL., APPELLANTS, v. GOWDY, COUNTY TREASURER, RESPONDENT, 62 Mont. 119; 203 P. 1115; 1922 Mont. LEXIS 5 (Montana Supreme Court 1922)
  23. ^ "Montana Man Refuses to Pay Bachelor Tax" (PDF). Batavia Daily Times. 1924-05-23. Event occurs at 16:00.
  24. ^ “The Tax on Bachelors”, The Social Hygiene Bulletin, v. 8, June 1921, p. 5.
  25. ^ "Montana's Bachelor Tax Declared Void." Milwaukee Sentinel. 12 January 1922.
  26. ^ ""Foreign News: Bachelor Tax."". Times. 1923-05-28.
  27. ^ "Italian Bachelor Tax". The Times, London. 1927-02-11.
  28. ^ V. De Grazia, How Fascism Ruled Women: Italy 1922-1945, Los Angeles, 1992, p. 44.
  29. ^ a b Pollard, John (2005). The Fascist Experience in Italy. Routledge. p. 81. ISBN 9781134819041. Retrieved 19 July 2021.
  30. ^ "Italian Bachelor Tax". The Times, London. 1928-01-08.
  31. ^ "Italian Bachelor Tax". The Times, London. 1928-03-15.
  32. ^ Schmitz-Berning, p. 122.
  33. ^ Friedrich Hartmannsgruber, Die Regierung Hitler volume 3 1936, Munich: Oldenbourg, 2002, ISBN 978-3-7646-1839-1, p. 17 (in German)
  34. ^ "Consider Plan of Bachelor Tax." Schenectady Gazette. 23 April 1934.
  35. ^ a b Chamie, Joseph; Mirkin, Barry (March 2, 2012). "Childless by Choice". YaleGlobal Online. Retrieved April 29, 2021.
  36. ^ a b c Turda, Marius (2009). "The biology of war: eugenics in Hungary, 1914-1918". Austrian History Yearbook. Vol. 40. Cambridge University Press.
  37. ^ a b c Ironside, Kristy (2017). "Between Fiscal, Ideological, and Social Dilemmas: The Soviet 'Bachelor Tax' and Post-War Tax Reform, 1941–1962". Europe-Asia Studies. Vol. 69, no. 6. pp. 855–78. Bulgaria attempted to institute a bachelor tax in 1943 but the measure proved controversial and was eventually abandoned (Baloutzova [2], pp. 222–23, 236–43). In 1968, it introduced a socialist version for both sexes similar to the Soviet model (Brunnbauer & Taylor [ 4], p. 301)... the bachelor tax does not stimulate population growth but, just the opposite
  38. ^ Semiz, Yaşar (2010). "Turkey's Population Growth Policy During the 1923-1950 Period and the Issue of Compulsory Marriage Law (Bachelor Tax)". Selçuk Üniversitesi Türkiyat Araştırmaları Dergisi. Vol. 27. pp. 423–469.
  39. ^ a b ""Celula de bază a societăţii, oficial indivizibilă". Archived from the original on 2015-02-11. Retrieved 2015-02-11.." Jurnalul Național, 13 Mar 2009. Online.
  40. ^ "Stanley, Alessandra (16 November 1999). "Vastogirardi Journal; Blissful Bachelorhood and the Shrinking Village". The New York Times. Retrieved 2015-02-11.." New York Times. 16 November 1999.
  41. ^ Hemphill, C. Dallett (September 2011). "Reviewed Work: Sex and the Eighteenth-Century Man: Massachusetts and the History of Sexuality in America by Thomas Foster". Journal of the History of Sexuality. Vol. 20, no. 3. pp. 630–634. showing more change over time in attitudes towards unmarried men. While Foster refers to newspaper jests about a bachelor tax, for example, McCurdy tells their actual story. Foster does intervene in the acts versus identities debate over homosexuality
  42. ^ Blount, Jackie M. (2000). "Spinsters, Bachelors, and Other Gender Transgressors in School Employment, 1850-1990". Review of Educational Research. 70 (1): 83–101. doi:10.2307/1170595. JSTOR 1170595. "A bachelor is consider 'odd' or 'peculiar,' vain, selfish, and even a delinquent member of society" At the time, the terms "odd" and "peculiar" (especially when wrapped by quotation marks) were sometimes used as code for "homosexual" in polite conversation.
  43. ^ Miriam King and Steven Ruggles (Winter 1990). "American Immigration, Fertility, and Race Suicide at the Turn of the Century". Journal of Interdisciplinary History. No. 20. p. 348.
  44. ^ Carl Ipsen (September 1998). "Population Policy in the Age of Fascism: Observations on Recent Literature". Population and Development Review. Vol. 24, no. 3. pp. 579–592.
  45. ^ Nicholas Farrell (2001-07-21). "Fascist family values". Vol. 287, no. 9024. Spectator.
  46. ^ Z., Goldman, Wendy (1993). Women, the state, and revolution : Soviet family policy and social life, 1917-1936. Cambridge: Cambridge University Press. ISBN 9780521458160. OCLC 27434899.{{cite book}}: CS1 maint: multiple names: authors list (link)
  47. ^ Avdeev, Blum, Troitskaya, Alexandre, Alain, Irina (1995). "The History of Abortion Statistics in Russia and the USSR from 1900 to 1991". Population: An English Selection. 7: 39–66. JSTOR 2949057.{{cite journal}}: CS1 maint: multiple names: authors list (link)
  48. ^ Rosenbaum, Dan T. (August 2000). "Taxes, the Earned Income Tax Credit, and Marital Status". CiteSeerX 10.1.1.202.1488.
  49. ^ Thompson, Steven C., and Randall K. Serrett (2002-12-01). "Tax Filing Status--Are Joint Tax Returns Always Best?". The National Public Accountant.{{cite news}}: CS1 maint: multiple names: authors list (link)
  50. ^ Montanari, I. (2000-01-01). "From Family Wage to Marriage Subsidy and Child Benefits: Controversy and Consensus in the Development of Family Support". Journal of European Social Policy.
  51. ^ Forcucci, Lauren E. (2010). "Battle for Births: The Fascist Pronatalist Campaign in Italy 1925 to 1938". Journal of the Society for the Anthropology of Europe (JSAE). Vol. 10, no. 1. pp. 4–13. the battle for births had failed by 1938. The birthrate actually went down between the years 1927 and 1934, along with the marriage rate.
  52. ^ Fisher, Hayley (2013). "The Effect of Marriage Tax Penalties and Subsidies on Marital Status". Fiscal Studies. Vol. 34, no. 4. pp. 437–65. JSTOR 24440312.
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