(concurring). I concur in the result reached by my brothers, but for somewhat different reasons.
*609Merely because the American Concrete Institute is largely supported by contributions from its members does not disentitle it to a tax exemption to which it otherwise would be entitled.1
Nor do I think it consequential that no research is done on the premises owned by the Institute. An organization which, like the American Concrete Institute, causes research to be undertaken by others and which collates, evaluates and disseminates the results of that research and other useful knowledge which it collects and organizes is, literally speaking, a scientific institution.2
The Institute’s publications are widely used by architects, engineers and others interested in this field of endeavor. One of its publications, Building Code Requirements for Reinforced Concrete, is the basis of governmental regulation of concrete construction in a large number of communities. The Institute is not a trade association. Its research and publication programs are not oriented toward business promotion or profit making, although they, no doubt, advance the use of concrete. The work of the Institute is in the public interest. But all legitimate endeavor, including admittedly business and commercial pursuit, is in the public interest.
Something more than serving the public interest is required to bring one claiming exemption as an educational or scientific institution within the “goals and policies sought to be implemented by CL 1948, § 211.7, as amended by PA 1963, No 148, (Stat Ann 1965 Cum Supp § 7.7), CL 1948, § 211.9, as amended by PA 1964, No 275, (Stat Ann 1965 Cum Supp *610§ 7.9).” David Walcott Kendall Memorial School v. The City of Grand Rapids (1968), 11 Mich App 231. In the cited case our Court declared that the general exemption under consideration may he availed of by an institution otherwise within its definition which makes a substantial contribution to the relief of the burden of government.3 Although the Court was then speaking of a claim of exemption' as an educational institution, on principle its holding has equal application to the claim at hand.4
The question is one of degree. Each case will turn on its own facts and circumstances. As we move beyond the traditional charitable objectives, those of providing relief to persons unable to care for themselves, education and religion, we scrutinize more carefully claims of exemption.
In this case the State tax commission found that the American Concrete Institute had not established that its contribution to the relief of the burden of government was sufficiently substantial to warrant the claimed exemption. That conclusion is justified by the record and comports with the construction of the statute given by our Court in David *611Walcott Kendall Memorial School v. The City of Grand Rapids, supra.
The Institute’s technical publications are, no doubt, enlightening to those interested in the latest in concrete technology, but it has not been shown that they, any more than countless like publications in countless other fields, represent a significant contribution to the relief of the burden of government. The Institute’s Building Code Requirements for Reinforced Concrete adopted in 1963 may well have relieved government or some government of the burden of producing standards needed to make possible meaningful governmental regulation of the use of concrete in construction, but that important work was completed before the current tax years; it has not been shown that any continuing review and revision of the code by the Institute since 19635 represents a significant contribution to the relief of the burden of government in current tax years.6 The work done in 1963 and prior years on the code does not entitle the Institute to an on-going exemption in futuro.
2 Cooley, Taxation (4th ed), § 739, pp 1545, 1546; 51 Am Jur, Taxation, § 602, p 585.
“A 'scientific institution,’ under the language of all civilized countries, means an institution for the advancement or promotion of knowledge, which is the English rendering of 'science’.” The Detroit Home & Day School v. The City of Detroit (1889), 76 Mich 531, 523.
No doubt it will not be necessary to establish that the work being done by the organization claiming charitable exemption actually has been undertaken by a particular unit of government or taxing body within whose boundaries the organization claiming exemption is located. In District of Columbia v. National Wildlife Federation (CA DC, 1954), 214 F2d 217, 219, the court declared that an institution claiming exemption as a scientific institution was not required to show that it performs a service of substantial character which otherwise the local government, or any other, would actually assume, but that when an exemption is claimed on that ground the court examines the institution’s “objects and activities in light of the purpose of the legislature to aid and encourage by tax exemption enterprises performing a public or quasi-public service.”
The relief of the burden of government test stated in the Kendall School case applies where the organization seeks exemption, as does the American Concrete Institute, as an educational or scientific institution. The principle stated in Kendall School harmonizes preceding Michigan Supreme Court cases discussing the scope of the exemption for educational and scientific institutions. The Kendall School principle need not, however, be applied where the organization seeks exemption under our statute as a charitable institution.
It appears that other particularized standards have been adopted by the Institute in various years between 1944 and 1965. The record does not show whether any of these are used by any government in its regulatory program, nor does the record show whether there has been any revision since 1963 of the Building Code Requirements for Reinforced Concrete.
Compare Dulles v. Johnson (CA 2, 1959), 273 F2d 362 (80 ALR2d 1338), certiorari denied (1960), 364 US 834 (81 S Ct 54, 5 L Ed 2d 60), and American Society for Testing and Materials v. Board of Revision of Taxes (1967), 423 Pa 530 (225 A2d 557), where the record showed that the organizations which there succeeded in obtaining exemption made a continuing contribution, including during the tax years before the court, in fields of endeavor where, but for that contribution, government would have had to step in and do the job that was being done by the organization in question. Contrast Massachusetts Medical Society v. Assessors of Boston (1960), 340 Mass 327 (164 NE2d 325).