Believing the majority has misapplied the rule from Board of Regents of Universities, Etc. v. City of Tempe, 88 Ariz. 299, 356 P.2d 399 (1960), on which they rely, I respectfully dissent. There, the City sought to directly regulate construction and maintenance of buildings on Arizona State University campus. The court found that the Board of Regents and the City both had constitutional and statutory authority to regulate the construction and maintenance of buildings on the campus, but held that a state agency duly performing a governmental function is not subject to the general police powers of a munici- ' pal corporation.
Here, no such interference with the functions of a governmental agency is involved. The business privilege tax is the obligation of the contractor. Arizona State Tax Commission v. Garrett Corporation, 79 Ariz. 389, 291 P.2d 208 (1955). Exemptions are not to be implied, though the burden is passed on to the government. Warren Trading Post Co. v. Moore, 95 Ariz. 110, 387 P.2d 809 (1963), reversed on other grounds by the United States Supreme Court in Warren Trading Post Co. v. Arizona State Tax Commission, 380 U.S. 685, 85 S.Ct. 1242, 14 L.Ed.2d 165 (1965); James v. Dravo Contracting Co., 302 U.S. 134, 58 S.Ct. 208, 82 L.Ed. 155 (1937); Arizona State Tax Commission v. Garrett Corporation, supra.
The judgment should be affirmed.