(dissenting). The majority opinion correctly concludes that the right to equal opportunity for education is a fundamental right under the Wisconsin Constitution and that the legislature is constitutionally mandated to provide an equal opportunity for education. We further agree with the majority that article X of the Constitution recognizes public education as a state function and at the same time requires funding of public education by both the state and local governments. However the majority erroneously concludes that the school district financing system set forth in secs. 121.07 and 121.08, Stats., violates art. VIH, sec. 1 of the Wisconsin Constitution which provides that “the rule of taxation shall be uniform.”
I.
This court has on numerous occasions stated that all legislative acts are presumed constitutional and that if any doubt exists it must be resolved in favor of the constitutionality of a statute. Our task is not to judge the merits of the statute or the wisdom of the legislature. Our task is to determine whether the statute clearly contravenes some constitutional provision. Gottlieb v. Milwaukee, 33 Wis.2d 408, 415-416, 147 N.W.2d 633 (1967). See also School Dist. v. Marine Nat. Exchange Bank, 9 Wis.2d 400, 403, 101 N.W.2d 112 (1960); State ex rel. Thomson v. Giessel, 265 Wis. 207, 215-216, 60 *584N.W.2d 763 (1953), 265 Wis. 558, 565, 61 N.W.2d 903 (1953); Chicago & N. W. Ry. v. La Follette, 27 Wis.2d 505, 521, 135 N.W.2d 269 (1965).
As stated in Payne v. Racine, 217 Wis. 550, 561, 259 N.W. 437 (1935):
“Before a statute can be said to be unconstitutional, the statute must lack in public purpose ‘so clear and palpable as to be perceptible by every mind at the first blush.’ This was said by Chief Justice DIXON, who sat in the constitutional convention and helped frame the charter of our state. Brodhead v. Milwaukee, 19 Wis. *624, *652. ‘We must bear in mind,’ said Chief Justice WINSLOW, ‘the well-established principle that it [the statute] must be sustained unless it be clear beyond reasonable question that it violates some constitutional limitation or prohibition.’ Borgnis v. Falk Co., 147 Wis. 327, 348, 133 N.W. 209. ‘The rule of all courts,’ said Mr. Justice BARDEEN, ‘is that a statute will be declared unconstitutional only when it. is shown beyond reasonable doubt that it conflicts with the fundamental law. It is equally true that the courts will seek every reasonable mode of reconciliation of the statute with the constitution, and it is only when reconciliation has been found impossible that it will be declared void.’ State ex rel. Hicks v. Stevens, 112 Wis. 170, 172, 88 N.W. 48.”
We do not believe that the majority has accorded this statute the proper presumption of constitutionality. It is not clear beyond reasonable question that the statute conflicts with the constitution. “If there was any doubt as to the power, duty would require us to resolve such doubt in favor of the validity of the act.” State ex rel. New Richmond v. Davidson, 114 Wis. 563, 579, 580, 88 N.W. 596, 90 N.W. 1067 (1902).
The majority concedes that equality of educational opportunity is a legitimate legislative goal, that a statewide property tax could be levied to support our schools, provided the rate is uniform, and that local districts should have some local control and some power to raise *585additional revenue by local taxation. The legislation before us is an innovative attempt to accommodate these concepts while at the same time preserving to individual districts a significant measure of local control over the quality and financing of education. The majority today uses doctrines designed and heretofore employed to prevent unjust impositions of the tax power to strike down a law which may offend the proprietary views some taxpayers have come to hold regarding school district revenues, but which certainly does not offend either the letter or the spirit of the Constitution.
II.
The majority holds that the statute in question violates art. VIII, sec. 1, Wis. Const., which states in part that “the rule of taxation shall be uniform.” The majority notes — and we agree — that this clause has been interpreted to mean that the rate of taxation for property must be uniform throughout the territorial limit of the unit imposing the tax.1 The statute under attack here complies with the principle of territorial uniformity since the rate of taxation in each school district is the same for all property located therein.2
*586Several early Wisconsin cases interpreted the uniformity clause more broadly than merely territorial uniformity. These cases said that the uniformity clause required that taxes be levied and expended only for public purposes (in contrast with private purposes) and that a state-wide tax be levied only for a state-wide purpose, a county-wide tax for a county purpose and so on, down to the smallest unit.3
However, later cases of this court have categorized the principle that tax revenues be spent at the level at which they are raised as being part of the public purpose doctrine.4 This court has recognized that the public purpose *587doctrine is a well-established limitation on the power of taxation, which is not derived from the uniformity clause or from any other specific constitutional provision.5 The public purpose doctrine is an inherent limitation on taxation which is variously attributed to the nature and form of our government, the reservations of *588individual rights, and the concepts of equity, fairness and due process.6
The reason this court has at times derived the public purpose doctrine from the uniformity clause is that the basic rationale of the uniformity clause is the same as that of the public purpose doctrine.
The uniformity clause guarantees that the burden of supporting government will be fairly and equitably ap*589portioned among the citizens. In Weeks v. Milwaukee, 10 Wis. 186 (*242), 201 (*257) (1860), this court declared that the uniformity clause is “to protect the citizens against unequal, and consequently unjust taxation.” In Knowlton v. Supervisors of Rock County, 9 Wis. 378 (*410), pp. 387-388 (*419-*420) (1859), it was stated:
“. . . The theory of our government is, that socially and politically all are equal, and that special or exclusive, social or political privileges or immunities, cannot be granted, and ought not to be enjoyed. In consonance with this theory, that of taxation, whether as the subject of legislative action, judicial inquiry, or constitutional law, has always been that the burdens of supporting the government should be borne equally by all the individuals composing it, in proportion to the benefits conferred, and that the tax payer receives for the money exacted, a just compensation by the protection afforded his person and property by the proper application of the tax. This principle of justice and equality which requires that each person should contribute towards the public expenses his proportionate share, according to the advantages which he receives, lies at the foundation of our political system; and, in our opinion, it was to give to it a greater permanency and force, and to secure its more rigid observance, that the section above quoted [Uniformity Clause] was introduced into the constitution.”
The issue for this court is therefore not a question of the application of the oft-interpreted uniformity clause— in the sense of territorial uniformity — which is clearly achieved in the statutes before us. The issue in this case is whether the “negative aid” statute violates the public purpose doctrine, the underlying aim of which is to protect citizens against an exercise of governmental power which is arbitrary and contrary to basic concepts of fairness and due process.7 In applying the public pur*590pose doctrine to determine the validity of a statute, we are not applying mechanical rules; we are determining whether the legislature violated fundamental rules of fairness and equity and should be prevented from levying unjust and unfair exactions.
III.
The public purpose doctrine, as enunciated by the majority, has two aspects:
1. The tax must be for a public — not a private— purpose.
2. The purpose of the tax must be one which pertains to the public purpose of the district within which the tax is to be levied and raised.8
That education in the public schools is a public, not a private purpose, is conceded, and no more need be said.
The heart of the majority opinion is that the negative aids law violates the second part of the rule. The majority contends that the law compels “one school district to levy and collect a tax for the direct benefit of other school districts, or for the sole benefit of the state” in *591violation of art. VIII, sec. 1, Wis. Const. As one can see from the holding of the majority and from the cases following, the rule that “taxes must be spent at the level at which they are raised” means only that there must be some correspondence between the taxing district or districts upon whom the burden of a given tax rests and the district or districts thought to be benefited by the expenditure of the proceeds. One taxing district cannot be taxed for the sole benefit of another taxing district.9 This court has said “ ‘there can be no legitimate taxation unless for the uses of the government’ levying it.”10
*592The public purpose limitation upon the tax power is not an arbitrary rule governing legislative power but is a doctrine of fairness whose purpose is to prevent fundamentally unjust and unfair exactions. The limited function of the judiciary in this regard must be kept firmly in mind, lest dicta and language used in prior cases be applied as if they and not the constitutional and inherent limitations on the legislature were the source of the doctrines to be applied. An analysis of the cases and the application of the rule to the specific fact situations will show that the negative aids legislation violates neither the public purpose rule nor this court’s prior decisions.
Lund v. Chippewa County, 93 Wis. 640, 67 N.W. 927 (1896), and State ex rel. Board of Education of City of Oshkosh v. Haben, 22 Wis. 629 (*660) (1868), are cited by the majority for the rule the state could not require *593one or more counties of the state, less than the whole, to support a state institution.11 A similar case was State ex rel. McCurdy v. Tappan, 29 Wis. 664 (1872), in which the court held that the state could not require Oshkosh to raise funds for furnishing soldiers to the United States Army. The act was invalid on two grounds: (1) it singled out one municipality; and (2) furnishing bounties to volunteers was not a municipal purpose. Thus the act violated the uniformity clause and the constitutional requirement (art. VII, sec. 2) that “the legislature establish but one system of town and county government which shall be as nearly uniform as practicable.” One of the purposes of the uniformity clause, said our court, “was to protect the taxpayers in any particular county or town from being compelled by the legislature without their consent to bear burdens in respect to matters not strictly *594municipal which other counties or towns are not required to bear.” Tappan, supra, at p. 679.
Thus the proposition for which Lunds Haben and Tappan stand is that the state shall not use its power to impose a tax on one local government — rather than all local governments — for state purposes without the consent of the local entity. The imposition of an extra tax burden solely on taxpayers of one unit was declared invalid. The rule established was that all local units — all taxpayers — should make a contribution to support the state purpose.
The negative aid law in question here applies across the state to all school districts. No one school district is singled out to support another school district or state education. Thus the negative aids legislation is substantially different from the statutes in the cases cited by the majority, and the application of those cases to our question is therefore questionable. However, it is important to note that the negative aids law does not contravene the quoted black-letter doctrines set forth in these cases. No taxpayer is relieved of his proportional contribution to the support of education. The goal of the legislation is that all Wisconsin taxpayers shall contribute their fair share to the support of public education, and all will be, relative to any given spending level, equally burdened. The fact that the result of the negative aid provision will be that some but not all districts will pay negative aid is not grounds for its invalidation. The rules governing aid payments apply to all school districts alike which meet the terms and conditions of the statute. Cf. Joint School Districts v. Sosalla, 3 Wis.2d 410, 420, 88 N.W.2d 357 (1957); Columbia Co. v. Wisconsin Retirement Fund, 17 Wis.2d 310, 322, 116 N.W.2d 142 (1962); West v. Tax Commission, 207 Wis. 557, 564, 242 N.W. 165 (1932).
Accordingly, we conclude that the statute before us meets the test set forth by these cases that the state not *595require one local unit to support a state institution or purpose. The next issue is whether the legislature is requiring the local school districts to raise and expend funds for a purpose which is not germane to the local school district in violation of the public purpose doctrine. 12 “The question is, therefore, narrowed to a single point: Is the purpose in this instance a public one — does it concern the common welfare and interest of the municipality?” Brodhead v. Milwaukee, 19 Wis. 658 (*624), 689 (*655) (1865). The majority opinion assumes— without any discussion — that a payment by a school district to the state for redistribution for education is not germane to any purpose of the school district making the payment. However, the Lund and Haben cases recognize the power of the local unit to raise funds for a state purpose. A local government raising funds for a state purpose does not violate the uniformity clause or public purpose doctrine — if it can be shown that the unit also has an interest in the state purpose.
That expenditures are made outside the district do not render the appropriation invalid because such expenditures may still be a valid school district purpose.13
In Sharpless v. Mayor of Philadelphia, 21 Pa. 147, 171, 172 (1858), a case relied upon by the majority, the *596court noted that the right of a local unit to fund public works was not confined to those works within the geographical unit whose people were taxed. The determinative factor is not the geographical location of the expenditure but the interest of the local unit and its people. The Pennsylvania court set forth the test as follows:
“. . . Local taxes for local purposes, and general taxes only for purposes which concern the whole state, are a vital principle of our political system, and there _ is no feature in it which has attracted more unqualified admiration from those who understand it best. Its justice is too obvious to need explanation. . . .
“The city’s charter was granted by the legislature. It may be enlarged. The same power which gave them the privileges which they have, may give them others. It cannot be so enlarged as to enable the corporate authorities to embark the city in a private business, or to make the people pay for a thing in which they have no interest. But within these limits there is nothing to prevent an indefinite extension of their corporate powers.
“But it is insisted that the right of a city or county to aid in the construction of public works, must be confined to those works which are within the locality whose people are to be taxed for them. The Water-Gap Company stops its road north of Vine street, outside of the city limits, and the Hempfield road has its eastern terminus at Greensburg, three hundred and forty-six miles west of Philadelphia. I have already said that it is the interest of the city which determines the right to tax her people. That interest does not necessarily depend on the mere location of the road. Therefore the location cannot be an infallible criterion. ... A railroad may run through a county without doing its inhabitants the least service. May such a county assist to make it, while a city which it supplies with bread and whose trade is doubled by it must not do so, merely because it ends outside of an imaginary line that limits the corporate jurisdiction? It seems very plain that a city may have exactly the same interest in a road which terminates outside of her borders, as if the depot were within them, and a great deal more than if it passed quite through. If she has an interest in any *597part, she has probably an equal interest in every part.” (pp.171-172)
Even if there is a national or state interest, the courts have recognized that there can also be a local interest— which the local unit has in common with the whole state— sufficient to sustain or authorize the local tax. In Sharp-less the court decided that the city had a special local interest in the improvements outside the city limits.
In Brodhead, supra, at p. 674 (*639-*640), it was argued that Milwaukee has no obligation to pay soldiers who entered the service of the United States. “They are not the soldiers of Milwaukee, but of the nation .... In what view, then, will taxation to pay these bounties be justified? Is its object to fill up the national armies and put down rebellion? This is not a matter of local or municipal duty or concern.” This court upheld the law finding a municipal purpose although national and state interests were present.
These cases support the rule that a local interest, even one which a local unit has in common with the state, is sufficient to justify local taxation. The courts have repeatedly said that if the local unit has any such local interest, then the question of taxation is for the legislature and not for the courts. In Brodhead (p. 686, *652) this court said:
“. . . The objects for which money is raised by taxation must be public, and such as subserve the common interest and well being of the community required to contribute. To justify the court in arresting the proceedings and declaring the tax void, the absence of all possible public interest in the purposes for which the funds are raised must be clear and palpable — so clear and palpable as to be perceptible by every mind at first blush.”
In Sharpless, supra (p. 172), the Pennsylvania court similarly gave great weight to the legislative determination if one could find any special local purpose.
*598“But it is not our business to determine what amount of interest Philadelphia has in either of these improvements. That has been settled by her own officers, and by the legislature. For us it is enough to know that the city may have a public interest in them, and that there is not a palpable and clear absence of all possible interest perceptible by every mind at the first blush. All beyond that is a question of expediency, not of law, much less of constitutional law.”
If the majority (and petitioner) are saying that the payments to the state are invalid because property receiving no direct benefit from a tax for a particular purpose should not be taxed for that purpose, this position is not defensible. A citizen must pay a proportion of a school tax although he or she has no children. As Cooley on Taxes so aptly states:
“No system of taxation has yet been devised which will return precisely the same measure of benefit to each taxpayer or class of taxpayers in proportion to payment made, as will be returned to every other individual or class paying a given tax; and it follows that neither the federal nor state courts have power to revise the taxing system of a state for the purpose of attempting to produce a more just distribution of the burdens of taxation than that arrived at by the legislature.” (Sec. 89, p. 216)
The question then is whether there is a local public purpose which rationally justifies the legislative enactment requiring the local school districts to return some revenues raised by school taxes to the state.14
*599IV.
We conclude that the local property tax system which will result from the new formula, including the negative-aid provisions, does not violate the public purpose rule. We are unwilling to say that school districts, as a matter of constitutional law, have an absolute, unqualified right to the full revenues raised by the property tax within their districts.15
*600First, we note that the appropriate focus in testing whether the public purpose rule is violated is to look at the entire property tax and not merely the tax proceeds which must be paid to the state as negative aids. Under the new formula, the bulk of the funds raised by the local property taxes continues to be spent within the school districts in which they are raised.
Secondly, we must determine whether the negative aids formula in fact compels one school district to contribute to a purpose confined to another district. As this court asked: “Can the citizens of Dane County be thus compelled to contribute to any public purpose *601confined to the county of Marinette or St. Croix?”16 We believe the legislature has reasonable grounds to conclude that contribution by a school district to the Department of Public Instruction of part of its locally raised property tax revenue which shall then be distributed as state educational aids to school districts, is in the interest of and is germane to the purposes of the contributing school district.17 The taxpayers should not be heard to complain because a fraction of the taxes they pay for school purposes benefit the state’s school system, of which the school districts in which they reside are a part.
School districts are merely quasi-municipal bodies and agents of the state for the purpose of administering the state’s system of public education and have only such powers as are conferred upon them expressly or by necessary implication.18 Public education is a state, not a *602local function, by virtue of the explicit command of the state constitution,19 the express enactment of the legislature,20 and the repeated pronouncements of this court over the years.21
It is true that school boards have a very large measure of local control, but it is the legislature, and not the constitution, which creates the specific dimensions of this local control.22 Over the years the legislature has encouraged local control of the educational system. Nevertheless each local school unit is not an isolated entity unto itself. Each unit must meet state requirements and is subject to the supervision of the Department of Public Instruction. Each unit is part of the whole state educational system.
We believe it an inevitable conclusion that the purpose of each school district is not only to educate its own children but also to participate in a state-wide educational *603system. Local school district purposes, for which local tax revenues may properly be spent, are not circumscribed by school district boundaries.
This was recognized as true of school districts in Ohio in Miller v. Korns, 107 Ohio St. 287, 140 N.E. 773 (1923). The statutes there involved had the effect of transferring a sizable portion of the property tax revenues of the school district in which the plaintiff resided out of that district for the benefit of other districts. A claim similar to that made here was raised:
“Plaintiff next contends that as the money raised in Silver Lake village school district is taken out of that district and used in other school districts in Summit county, it is employed for a purpose foreign to the school district of Silver Lake village, and hence for a purpose which is not legitimate in taxation.” (p. 297)
In the course of rejecting this contention, the Ohio court said:
“. . . Silver Lake village school district shares in the advantages which will be derived from uniform excellence of schooling in Summit county and in the state of Ohio. The state purpose of having efficient schools throughout the borders of Ohio is a purpose not foreign to Silver Lake village school district nor to any other school district, but is one which, seen in the proper light, belongs to every school subdivision in Ohio.” (p. 299)
What was said of school districts in Ohio is equally true here.
Activities within a given school district are of interest and concern to and serve a purpose common to other districts. There is mobility of population and transfer of students; there is movement of children within the state and students attend school outside the school district of residence.23 Moreover one school district may provide *604education of its pupils in another school district on a tuition basis. Sec. 120.13(4), Stats.
The legislature has created cooperative educational service agencies24 and has divided the state into CESA *605territories, each of which is multi-county and embraces many school districts.25 Each CESA is governed by a board of control consisting of up to eleven representatives of the school districts in the agency’s territory. The legislature stated that such agencies are:
“. . . designed to serve educational needs in all areas of Wisconsin and as a convenience for school districts in co-operatively providing to teachers, students, school boards, administrators and others, special educational services including, without limitation because of enumeration, such programs as research, special student classes, data collection, processing and dissemination, in-service programs and liaison between the state and local school districts.”26
The board of control appoints an Agency School Committee within each agency territory. The Committee is given the responsibility of studying and evaluating the existing school district structure
“. . . to determine if the goals of equal and improved educational opportunities for all children within the agency territory have been attained . . . and [to formulate] a plan to strengthen the administrative districts of the agency territory to operate a comprehensive school *606program of offerings and services which meet the present and future educational needs of the children of the state and which can function with efficiency and at a justifiable cost to the local taxpayers and to the state.”27
See. 20.255(1) (fc), Stats., provides state aids for the development of data processing services on a regional basis. Thus school districts are not isolated entities, either in terms of delivery of educational services therein or in terms of assessing the quality of performance in delivery of such services. An interdependency of purpose among school districts is implicit in the statutes dealing with education. Given these factors, it can hardly be said that a partial diversion of local tax revenues to the state for redistribution to other districts is constitutionally invalid.
Some might argue that the reasoning set forth above, pushed to its logical conclusion, means that every state benefit is of local concern and that any state direction for a local unit to turn over funds raised at the local level will therefore be valid. Such a conclusion does not necessarily follow from this opinion. In large part, it is the uniqueness of education among all public activities which supports this negative-aid system.
“. . . [T]here can be no uniform rule which is not at the same time an equal rule, operating alike upon all the taxable property throughout the territorial limits of the state, municipality or local subdivision of the government, within and for which the tax is to be raised.” Knowlton v. Supervisors of Rock County, 9 Wis. 378 (*410), 389 (*421) (1859). “. . . In Knowlton the court held that once property is selected for taxation it must be taxed in its entirety and the same rate must be applied to it as to all property in the tax district.” Gottlieb v. Milwaukee, 33 Wis.2d 408, 419, 147 N.W.2d 633 (1967). See also- Newhouse, Constitutional Uniformity & Equality in State Taxation, pp. 234-248 (1959).
The uniformity clause of the constitution applies only to assessment and taxation and does not control the expenditure of *586money arising out of any assessment or taxation of property. Sawyer v. Gilmore, 109 Me. 169, 83 Atl. 673 (1912); Kerr v. Perry School Tp., 162 Ind. 310, 70 N.E. 246 (1904) ; State ex rel. Woodward v. Moulton, 57 Mont. 414, 189 Pac. 59 (1920).
“It is quite impossible for us to perceive in what way it can be argued that this legislation violates the rule of uniformity in taxation of property. This rule was placed in the constitution for the protection of the taxpayer so that there may be no discrimination in property taxation. There is none here. The law does not change in the least the taxpayer’s burden. He pays exactly the same tribute whether his whole tax contribution remains in the state treasury or whether part of it goes to the city treasury. He has not been taxed at one rate on a part of his property and at a higher rate upon another part ....
“It is equally difficult for us to see how this law can be in any sense called a law for the assessment or collection of a tax. It does not become effective for any substantial purpose until after the assessment and collection of the tax are fully completed. The processes of assessment and collection remain the same in operation and in effect as before.” State ex rel. Superior v. Donald, 163 Wis. 626, 628, 629, 158 N.W. 317 (1916).
State ex rel. New Richmond v. Davidson, 114 Wis. 563, 578, 90 N.W. 1067 (1902) ; State ex rel. Garrett v. Froehlich, 118 Wis. 129, 140, 94 N.W. 50 (1903).
“. . . The requirement of a public purpose obviously applies to all forms of taxation, whether levied by the State or any of the subdivisions of the State to which the power of taxation may be delegated, and whether the tax is general in the State or munici*587pality, or special, that is, levied by way of special assessment in limited taxing districts created for public improvements. Whatever the form of the tax, it is inherent in its nature that it must be levied for a public, as distinct from a private, purpose; and it also must be public in the sense that the purpose must pertain to the district taxed, that is, the tax levied upon the entire State must be for a general public purpose as distinguished from a distinctively local or municipal purpose. On the other hand, a tax cannot, or rather should not, be levied upon a particular district of a State alone for a general public purpose not peculiar to the district taxed.” Judson on Taxation, see. 391, pp. 413-414 (1917).
State ex rel. Wisconsin Devel. Authority v. Dammann, 228 Wis. 147, 183, 277 N.W. 278, 280 N.W. 698 (1938); State ex rel. American Legion 19411 Conv. Corp. v. Smith, 235 Wis. 443, 451, 293 N.W. 161 (1940); State ex rel. Singer v. Boos, 44 Wis.2d 374, 381, 171 N.W.2d 307 (1969); State ex rel. Warren v. Nusbaum, 59 Wis.2d 391, 413, 414, 208 N.W.2d 780 (1972).
“It is a maxim of the law that the power to appropriate is coextensive with the power to tax and so has fundamental and inherent limitations.
“The first of such limitations is implied from the very nature of organized society. That exists for public purposes of a governmental character. The scope of such purposes, it must be conceded, except as expressly or by necessary implication fundamentally limited, is quite broad.
“It follows that we need not, necessarily, depend on any fundamental limitations of the power to tax. There would be such if we had no constitution. Then, a tax could not properly be levied to take property from one person and give it to another.
“Public purpose and the character of the tax otherwise, would determine its legitimacy. A state-wide tax could only be levied for state-wide purposes and so on down to the smallest taxing district. In either case, the purpose would need to be public, in the sense of a matter of common or general interest to those *588npon whom the burden is laid.” State ex rel. Owen v. Donald, 160 Wis. 21, 124, 125, 161 N.W. 331 (1915).
The origin of the public purpose doctrine has been variously attributed by this court to- the due process and equal protection clauses of the state and federal constitutions, State ex rel. Wisconsin Development Authority v. Dammann (1938), 228 Wis. 147, 277 N.W. 278, 280 N.W. 698; art. IV, see. 4, of the United States Constitution, which guarantees to every state a republican form of government, Heimerl v. Ozaukee County (1949), 256 Wis. 161, 40 N.W.2d 564; and art. VIII, sec. 2, of the Wisconsin Constitution which provides that no money shall be paid out of the treasury except in pursuance of an appropriation by law. State ex rel. La Follette v. Reuter (1967), 33 Wis.2d 384, 147 N.W.2d 304. Other authors have attributed the doctrine to judicial articulation of the belief that governmental power should be used for the benefit of the entire community. Mills, The Public Purpose Doctrine in Wisconsin, 1957 Wis. L. Rev. 40.
See also: State ex rel. Bowman v. Bairczak (1967), 34 Wis.2d 57, 62, 63, 148 N.W.2d 683; Eieh, A New Look At The Internal Improvements And Public Purpose Rules, 1970 Wis. L. Rev. 1115.” State ex rel. Warren v. Nusbaum, 59 Wis.2d 391, 413, 414, n. 8, 208 N.W.2d 780 (1972).
The needed protection against arbitrary legislative action may be found in the state and federal equal protection limitations. Newhouse, supra, pp. 601-608. “[T]he decisions of this court, as well as a half century’s practical construction, reinforce the conclusion so strongly suggested by the constitutional debates . . . that the clause ‘The rule of taxation shall be uniform’ if applicable to excise taxation at all, means no more than the general equality clauses of the constitution, or “the equal protection of the law’ guaranteed by the XIVth amendment.” Nunnemacher v. State, 129 Wis. 190, 220, 108 N.W. 627 (1906). See also Judson, supra, note 4.
“. . . A state tax law will be held to conflict with the Fourteenth Amendment only where it proposes, or clearly results in, such flagrant and palpable inequality between the burden im*590posed and the benefit received, as to amount to the arbitrary taking of property without compensation — ‘to spoliation under the guise of exerting the power of taxing.’ ” Dame v. Jackson, 256 U.S. 589, 599, 65 L. Ed. 1107, 41 Sup. Ct. 566, aff’g 237 Mass. 60, 129 N.E. 606. Cooley on Taxation, sec. 89, p. 216 (4th ed. 1924).
A shorthand statement of this rule also used by the majority is that the tax must be spent at the level at which it is raised. This shorthand statement of the rule cannot be taken literally. Since its inception this state has returned general revenue raised at the state level to local school districts to be spent there. Conversely, our statutes expressly require localities to raise property tax revenues and remit them to the state. See secs. 70.60, 70.63, Stats. It cannot be contended that these practices of long standing are invalid, provided state revenues, by whomever spent, are spent in aid of a state purpose.
Cooley on, Taxation, secs. 314-317, p. 650 et seq. (4th ed. 1924). See Tennant v. Sinclair Oil & Gas Co., 355 P.2d 887 (Wyo. 1960) striking down a tax levied by a school district and used to fund high schools in other districts. See also Sweetwater Co. v. Hinkle, 491 P.2d 1234 (Wyo. 1971), 493 P.2d 1050 (1972), where the court challenged the state educational financing scheme.
State ex rel. Owen v. Donald, 160 Wis. 21, 127, 151 N.W. 331 (1915). The court further said: “In these citations, and many more which might be referred to, the principle will be found declared which has been incorporated into most elementary works. Where there is no public purpose, in the sense of carrying on some part of the machinery of government, there is no power to tax. As put by the federal supreme court in Loam, Asso. v. Topeka, [20 Wall. 655, 670], an object which is not within the purposes for which governments are established, falls outside the limitation upon the right to take the property of the citizen, by way of taxation, for public use.” (p. 125)
Petitioners rely heavily upon the 1952 Nebraska case of Peterson v. Hancock, 155 Neb. 801, 54 N.W.2d 85 (1952), to sustain their position. In Peterson a county Blanket Mill Levy was imposed upon the school districts within each county, but the law provided that a district with less than five students would not receive any funds from this levy after the first year of operation of the law. The purpose of this portion of the law was to effect the consolidation of small school districts. The Nebraska Supreme Court concluded that the law violated the constitutional principle here in question because it levied a tax upon districts with less than five students for the exclusive benefit and local purpose of districts with more than five students. Yet the tax in question was a county tax, and, in Wisconsin at least, the appro*592priate inquiry would be whether or not the purpose of this county tax pertained to the county taxed. Since the funds raised did benefit districts within the county taxed, the constitutional rule would not have been violated in Wisconsin. See also Board of Tes. Jt. Class A School Dist. v. Board of Co. Comm,., 83 Ida. 172, 359 P.2d 635 (1961).
In Rinder v. Madison, 163 Wis. 525, 158 N.W. 302 (1916), Dane County, pursuant to state law, levied a tax on all taxable property in Dane County for the county highway fund. The city of Madison objected to the tax on the ground that the county was levying a tax for the county highway system which excluded city streets. Thus the city residents objected that they were subjected to a tax conferring a benefit on residents of towns and villages, contrary to the rule of uniformity and equal protection of the law. This court upheld the tax. Taxation is not limited to property directly benefiting from the purpose for which the taxes are raised. The justice or injustice of the limits of the taxing district when fixed by the legislature cannot be questioned by the court. “The alleged injustice to residents of cities by compelling them to contribute to the improvement of highways located outside of their municipal territory presents no constitutional objections, and if actual inequalities of burdens result that is a subject for legislative consideration.” (p. 531)
Another aspect of the public purpose doctrine — not in issue here — is whether the state can expend funds for purely local purposes. The majority quotes from and relies on State ex rel. New Richmond v. Davidson, 114 Wis. 563, 88 N.W. 596, 90 N.W. 1067 (1902), which involved this issue. In that case the state appropriated funds to the city of New Richmond to aid it in expenses incurred as a result of a cyclone. The appropriation was challenged on the ground that the state was taxing all citizens for private and local purposes — not for public and statewide purposes. The court said (p. 578):
“If the object of the appropriation in question was purely local to the city of New Richmond, then the rule of uniformity would require the tax to supply the same to be limited to that municipality. If, however, the contribution was to subserve the common interest and well-being of the people of the state, then the appropriation was legitimate.”
The court held that the state appropriation was valid because helping the city and people of New Richmond served the common interest and well-being of the state at large. This court took a broad and liberal view of state purpose to uphold the legislative determination. The New Richmond case involved a state tax and state expenditure; it did not involve a local tax or local expenditures.
The question what is a local purpose cannot be answered by any precise definition; the answers change to meet new developments and changing conditions. 15 McQuillin, Municipal Corporations, sec. 39.19, p. 32; vol. 16, see. 44.35, p. 97.
“And, to give locality to a purpose in respect to which a public expenditure is to be made, it is not essential that the public work created by means thereof should have its situs within the district. It is the district’s interest in the improvement, and not its location, which is the test whether an object is or is not a proper subject of district taxation.” Maltby v. Tautges, 50 Minn. 248, 253, 52 N.W. 858, 860 (1892). Cf. State ex rel. Americam, Legion 1941 Conv. Corp. v. Smith, 235 Wis. 443, 452, 293 N.W. 161 (1940). Gray, Limitations of Taxing Power and Public Indebtedness, p. 246, et seq. (1906).
“If a public purpose can be conceived which might rationally be deemed to justify the act, the court cannot further weigh the adequacy of the need or the wisdom of the method.” State ex rel. Zillmer v. Kreutzberg, 114 Wis. 530, 549, 90 N.W. 1098 (1902).
“It is undoubtedly the duty of the legislature which imposes or authorizes municipalities to impose a tax, to see that it is not to be used for purposes of private interest instead of a public use, and the courts can only be justified in interposing when a violation of this principle is clear and the reason for *599interference cogent. And in deciding whether, in the given case, the object for which the taxes are assessed falls upon the one side or the other of this line, they must be governed mainly by the course and usage of the government, the objects for which taxes have been customarily and by long course of legislation levied, what objects or purposes have been considered necessary to the support and for the proper use of the government, whether state or municipal. Whatever lawfully pertains to this and is sanctioned by time and the acquiescence of the people may well be held to belong to the public use, and proper for the maintenance of good government, though this may not be the only criterion of rightful taxation.” Citizens’ Savings & Loan Asso. v. Topeka, 20 Wall. 655, 664, 665, 22 L. Ed. 455 (1874).
“The rule that the benefits to the public must be direct and not remote and that the past course or usage of government is to be resorted to for guidance must in each case be considered in the light of the principle that the legislature has a very wide discretion to determine what constitutes a public purpose, and that courts will not interfere unless at first blush the act appears to be so obviously designed in all its principal parts to benefit private persons and so indirectly or remotely to affect the public interest that it constitutes the taking of property of the taxpayers for private use. It is to be observed that the tendency of later eases is toward greater liberality in characterizing taxes or appropriations as public in purpose.” State ex rel. Wisconsin Dev. Authority v. Dammann, 228 Wis. 147, 182, 277 N.W. 278, 280 N.W. 698, 709 (1938).
Petitioners make an elaborate argument that art. X of the Wisconsin Constitution raises to a constitutional status the complete fiscal autonomy of local school boards, such that all locally levied school taxes must be spent in the district, and no disincentives may be imposed by the state to limit the spending dis-*600eretion of local school boards. No cases are cited to support these sweeping propositions, and art. X clearly does not contain any such broad view of district fiscal autonomy. Art. X, sec. 4, provides that “each town and city shall be required to raise by tax, annually, for the support of common schools therein a sum not less than one-half the amount received by such town or city respectively for school purposes from the income of the school fund.” The purpose of this section was to force the local units to support the schools, but only to the limits set forth therein. The section does not state that all taxes raised by the local unit must support common schools therein. Nor does art. X make education a local function. See text at notes 18-22, infra. Petitioner’s arguments on this point are strained and artificial, and we conclude that they should be rejected.
For cases in other jurisdictions indicating that local governmental units do not have complete fiscal autonomy over taxes raised within the unit, cf. School Dist. No. 12 v. Wasco Co., 270 Ore. 622, 529 P.2d 386 (1974) upholding ad valorem tax refunds to be paid by county though tax levied by and for benefit of single taxing district against contention of illegal imposition of burden on nonbenefitted districts; Intermediate School Dist. No. 105 v. Yakima Co., 81 Wash.2d 443, 503 P.2d 104 (1972) upholding statute requiring Yakima County to make office space available without rent to school district encompassing more than Yakima County against contention of violation of constitution that county taxes be expended only for county purposes; State ex rel. Woodahl v. Straub, 164 Mont. 141, 520 P.2d 776 (1974) upholding distribution of state educational funds raised through *601a general property tax against the contention that revenue must be expended in the county in which the revenue originates.
State ex rel. New Richmond v. Davidson, 114 Wis. 563, 90 N.W. 1067 (1902). (Emphasis added.)
Sec. 20.255(1) (k), Stats., provides that the negative aid payments under sec. 121.08(3) are appropriated to the Department of Public Instruction to be applied for the payment of educational aids under subchapter I of ch. 121, Stats.
Zawerschnik v. Joint County School Comm., 271 Wis. 416, 429, 73 N.W.2d 566 (1955); Iverson v. Union Free High School Dist., 186 Wis. 342, 353, 202 N.W. 788 (1925); State ex rel. Van Siraten v. Milquet, 180 Wis. 109, 113, 192 N.W. 392 (1923).
The respondent’s brief notes that periodically the legislature has changed the boundaries of school districts, whereby territory from one district is detached and ordered attached to another district. Such orders have frequently been opposed on the grounds that the school district’s valuation will decrease and that therefore their taxes will either increase or less money will be made available for education in that district. This court has rejected this argument holding that “whether the boundaries of a school district should be changed is not a question of law or fact for judicial determination, but is purely a question of policy, to be determined by the *602legislative department. . . . The courts have nothing to do with the policy, wisdom ... of such matters. . . Zawerschnik v. Joint County School Committee, supra, at p. 427. The state’s conclusion that territorial changes and tax dollars being shifted, as in the case of negative aids, are comparable and are a constitutionally valid legislative function has merit.
Art. X, sec. 1, Wis. Const., expressly provides that “[t]he supervision of public instruction shall be vested in a state superintendent and such other officers as the legislature shall direct; and their qualifications, powers, duties and compensation shall be prescribed by law . . . .”
Art. X, sec. 3, Wis. Const., expressly provides that “[t]he legislature shall provide by law for the establishment of district schools, which shall be as nearly uniform as practicable. . . .”
Sec. 121.01, Stats., provides as follows: “It is declared to be the policy of this state that education is a state function. . . .”
State ex rel. Wisconsin Lutheran High School Conference v. Sinar, 267 Wis. 91, 65 N.W.2d 43 (1954); State ex rel. Thompson v. Giessel, 265 Wis. 558, 61 N.W.2d 903 (1953); State ex rel. Harbach v. Mayor, 189 Wis. 84, 206 N.W. 210 (1926); State ex rel. Dudgeon v. Levitan, 181 Wis. 326, 193 N.W. 499 (1923).
See, for example, ch. 120, Stats., which gives local school boards a wide measure of discretion in many fiscal and administrative matters.
According to the Department of Public Instruction, during the school year 1974-1975, 29,085 students transferred from one *604school district in Wisconsin to another. This figure does not include students who moved from one district to another during the summer recess. Milwaukee’s experience is that a little less than one-half of the total number of students moving from one district to another make the move during the summer. Thus, one can estimate that approximately 50,000-55,000 students, out of a total school population of about 970,000, transferred from one Wisconsin school district to another in 1974-1975.
Ch. 116, Stats. The Wisconsin Department of Public Instruction publication entitled Wisconsin Cooperative Educational Service Agencies describes CESA as follows:
“On July 1, 1965, Wisconsin’s system of county superintendents of schools, elected by popular vote, came to an end. Successor to it in a redefined and altered role is a system of regional Cooperative Educational Service Agencies. . . .
“The geographical-political unit of responsibility for the county superintendency was the county. The agency’s area of operational responsibility is a group of adjacent school districts, which in all cases embraces territory in two or more counties. At the time of their discontinuance there were 51 county offices in operation. The new regional agencies include all of the state’s area in 19 units.
“For more than a century the county superintendent was a prominent figure in the affairs of Wisconsin Public Education. The statutes directed him to provide educational leadership, visit the schools, inquire into courses of study, keep informed in instructional procedures, advise school boards, advise teachers, certify valuation of school districts, make reports and investigations requested by the state superintendent and report the condition of the schools annually to the county board. Through the years a multitude of responsibilities associated with education and allied activities moved within the scope of the county office’s activity, either by law, default or tradition.
“In reading the Wisconsin law which established the agencies, it seems reasonable to conclude that the rationale for agency existence and function assumes that there are services which are needed in the development of a complete educational program in a *605local district which cannot be realistically supplied by the independent effort of that district. Therefore, to supply these services only as identified and authorized by the officials of school districts, a coordinating regional office is provided by the state.
"This intermediate unit thus places school district officials in Wisconsin in the position of looldng at education not only in terms of their local district’s program. They now find themselves involved with officials of other school districts in consideration of educational programs which transcend school district lines. Such activity could be interpreted as a regional approach to supplying the educational needs of children.”
For a map showing the geographical boundaries of each of the 19 Cooperative Educational Service Agencies and their office locations, see 1975 Blue Book, p. 417.
Sec. 116.01, Stats.
Sec. 116. 51(2), Stats.