Samuel Freeman Miller

“ It will readily be conceded that the language of the fourth section of the act of 1855 is broad enough for that purpose: 'All property, of whatever kind or description, belonging to or owned by said corporation, shall be for ever free from taxation for any and all purposes.' But the argument is, that since the constitution then in force only permitted the legislature to exempt from taxation the property, real and personal, used by the university, in immediate connection with its function of teaching, the statute must be limited to property so used. ”

“ They said that the legislature might exempt from taxation 'such property as they might deem necessary' (not for the use of schools, but) 'for school purposes.' The distinction is, we think, very broad between property contributing to the purposes of a school, made to aid in the education of persons in that school, and that which is directly or immediately subjected to use in the school. The purposes of the school and the school are not identical. The purpose of a college or university is to give youth an education. ”

“ If this were true in point of fact, the conclusion would be sound, as we have repeatedly held in this court. Railroad Company v. Rock, 4 Wall. 177; Railroad Company v. McClure, 10 id. 511; Knox v. Exchange Bank, 12 id. ”