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War Department
Bureau of Refugees, Freedmen and Abandoned Lands
Washington, December 21st 1865

Col. O. Brown
Asst. Commissioner
State of Virginia.

Colonel.
Try and struggle on till action is taken by Congress. I find that the President has not the power to set apart the lands. I will bring the matter before Congress as soon as possible. Please inform Capt. Wilder.

Respectfully 
O.O. Howard
Maj. Gen. Comr.