(concurring). I agree with the majority’s conclusion that the imposition of a one percent collection fee, pursuant to MCL 211.44; MSA 7.87, does not violate the Equal Protection Clause. Each person who timely pays his property taxes is required to pay the same percentage of the value of his property as a collection fee.
I write separately for two reasons. First, the majority opinion contains several statements sug*424gesting that the collection fee may be a tax and, if it is, it would be constitutional. If the collection fee was designed to raise revenue for general public purposes, rather than to cover specific governmental expenses, it is in reality a tax. Dukesherer Farms, Inc v Dep’t of Agriculture (After Remand), 405 Mich 1, 15-16, 20-21; 273 NW2d 877 (1979). If the one percent collection fee is a tax, MCL 211.44; MSA 7.87 violates Const 1963, art 4, § 32 because it does not distinctly state that the fee is a tax. Even if the fee was designed to reimburse local governments for expenses incurred in assessing real property and collecting property taxes, the amount of the fee (one percent) must reasonably approximate, the total amount spent on each parcel of property or the fee will be deemed a tax. City of Dearborn v State Tax Comm, 368 Mich 460, 472; 118 NW2d 296 (1962); Foreman v Oakland Co Treasurer, 57 Mich App 231, 237; 226 NW2d 67 (1974), lv den 394 Mich 815 (1975). These questions were properly raised in plaintiffs’ complaint, but were not decided by the trial court. I therefore would remand this case for a determination of whether the fee is a tax.
Second, the majority does not decide whether the collection fee was designed to cover the expenses of assessing property and collecting property taxes. The lower courts concluded as a matter of law that the fee covered only the costs of collecting taxes, i.e., the expenses incurred in preparing and mailing tax bills and processing payments. In response to this litigation, the Legislature amended MCL 211.44; MSA 7.87 by changing the term "collection fee” to "property tax administration fee.” 1982 PA 503, § 2, explains that this change was
intended to clarify the legislative intent and cure *425any misinterpretation surrounding the fact that a "collection fee” is imposed to cover all costs necessary and incident to the collection of property taxes, including the costs of assessing property values and in the review and appeal processes.
Since a determination of what expenses the one percent collection fee was designed to cover may be crucial to the issue whether the fee is a tax, I would decide this legal question.