The opinion
DOOLIN, Justice,
concurring specially:
I find no fault with the majority’s opinion as to taxability of the instant properties. I concur in that judgment. For myself, I would, under the doctrine of publici juris, go one step further. I would hold the Oklahoma Constitution does not authorize an exemption from ad valorem taxation to the intervenors as has heretofore been granted to them by the Garfield County Assessor or others in like position throughout the State of Oklahoma.
The adoption of § 6A 1 and the enactment of § 176 et seq. did not repeal or affect the validity of Art. V § 50 2 for there can be no doubt the basic premise and directive of our constitution is that no exemption except as otherwise provided by the constitution is allowable. Art. X § 6 is an authorized constitutional provision exempting property of the United States, the state, county and municipality and charitable use property from taxation.
I am not deaf to the strong arguments and excellent briefs of the respondent and intervenors, nor am I blind to the application of trust financing in existence throughout the state. Suffice to say I am impressed and persuaded Oklahoma’s Constitution and its legislative enactments create no exemptions to entities not enumerated therein.
*915 It is manifestly true that granting exemption from taxation results in increasing the burden upon less favored taxpayers; a state cannot and should not govern in this manner.
The Attorney General is correct in his conclusion contained in opinion, No. 79-168, dated July 31,1979. 3 The lessees occupancy and pursuit of profit, or for that matter other valid rights exercised during occupancy of a leasehold estate are interests in realty and taxable. Although admittedly not factually identical and not absolutely similar in statutory or constitutional directives, I find the rationale of the following cases and jurisdictions pursuasive in holding the leasehold estates of such entities as the intervenors and others similarly situated to be taxable. See Delta Airlines, Inc. v. Coleman, 219 Ga. 12 , 131 S.E.2d 768 (1963); Iron Co. v. State Tax Commission, 437 S.W.2d 665 (Mo.1969); Purcell v. City of Lexington, 216 S.W. 599 (Ky.App.1919); Cutter Flying Service, Inc. v. Property Tax Department, 572 P.2d 943 (N.Mex.App.1972) and San Pedro L.A. & S. L. R. Co. v. The City of L. A., 179 P. 393 (Cal.1919). 4
I would hold intervenors’ leasehold estates taxable without reliance on provisions attempting to qualify the ownership.
. We note that the Official Session Laws of 1968 as well as the annotated Constitution of Oklahoma contain two, § 6As one adopted September 17, 1968, and the other August 27, 1968. Our reference in this opinion is to § 6A adopted by the people on August 27, 1968.
. Art. V § 50: “EXEMPTION OF PROPERTY FROM TAXATION”
The Legislature shall pass no law exempting any property within this State from taxation, except as otherwise provided in this Constitution.
. All petitioners, including the Attorney General and numerous school districts within Oklahoma have presented this court with a challenge to the correctness, application and interpretation of the Constitution of Oklahoma (Art. X §§ 6, 6A) and the statutory enactments (60 O.S.I971 § 176 et seq.).
Likewise have the respondent and interve-nors raised such a question under Attorney
General’s opinion No. 79 168. We can and should answer their challenges.
. For an annotation reference tax exemption to property held on lease from exempt owner, see Mitchell Aero, Inc. v. City of Milwaukee, 42 Wis.2d 656 , 168 N.w.2d 183, 54 A.L.R.3d 391, 402 (1969).