had negligible commercial value. The Benefices Act 1898 (Amendment) Measure 1923 phased out advowsons so that they could not be sold or inherited after two vacancies occurred after 14 July 1924 and enabled their elimination earlier by direction of the current patron. It had the effect, however, in the words of the then Archbishop of Canterbury, Cosmo Lang, in 1933, "that the sale of advowsons very rapidly increased. Patrons were eager to sell, and were advised to sell, while their proprietary rights had still some financial value, and there can be no doubt the opportunity was used very largely to secure advowsons for party purposes and for party trusts.". The purchase of advowsons to ensure that a parish became an Anglo-Catholic, or more often Evangelical, stronghold, had begun in the 19th century. It led to a number of situations where an incumbent was imposed on a parish, and had been partly dealt with by the establishment of Diocesan Boards of Patronage in 1932. The rich body of common law regarding advowsons can sometimes become relevant in modern times when dealing with disputes over modern incorporeal hereditaments, such as farming allotments, that are not handled by statute or adequately settled by other common law. An example is the 1980 case of First Victoria National Bank v. United States. Value Advowsons were valuable assets for a number of reasons, principally as a means for the patron to exert moral influence on the parishioners, who were his manorial tenants, through the teaching and sermons of the parish priest. The manor was a business enterprise, and it was important for its commercial success that all who lived there should live and work in harmony for a common purpose, and should obey the law of the land and of the manorial court. Such a law-abiding attitude could be fostered by a suitable parish priest, and clearly the appointment of a priest who preached against this would be a disaster for the interests of the lord of the manor. An appointment could also be used to provide an income for a valued servant in holy orders (such as a chaplain or secretary), or as a reward for past services rendered to the patron by the appointee. A benefice generally included use of a house, i.e. a vicarage, parsonage or rectory, as well as the income from the glebe and tithes, which would provide for the living