Hallows, C. J.
Aero is engaged in a noncommercial aviation business at General Mitchell Field and constructed Hangar No. 3 Addition in 1962 at its own expense on land leased from the county. It reported the building as its property for tax purposes from 1962 through 1965; Hangar No. 4 was constructed by Aero at its own expense between September 2, 1965, and April 12, 1966, also on land leased from the county. This lease is dated September 2, 1965, and it is claimed by Aero that under the terms of this lease and of a bill of sale the hangars are owned by the county within the meaning of sec. 70.11 (2), Stats.1
[659]*659The basic issues on this appeal are: (1) What is the meaning of the word “owned” in the phrase “property owned by any county” in sec. 70.11 (2), Stats.; and (2) does the lease and other facts constitute the county of Milwaukee the owner within the meaning of that section ?
We start with the conceded fact that legal title to the hangars is in the county. Aero contends the word “owned” in the section means “title” and relies principally upon Aberg v. Moe (1929), 198 Wis. 349, 224 N. W. 132, 226 N. W. 301. It is quite true in this case the court construed the word “owned” in sec. 70.11 (1), Stats., exempting state-owned property from taxation, to mean bare legal title rather than beneficial ownership. In Ah erg, a co-op conveyed land and buildings to the board of regents of the university in consideration of a lease back for a term of thirty years. The city of Madison assessed the leasehold interest to the co-op. This court, in holding the legislature had not authorized a property tax on a leasehold, stated the city of Madison had no right to go behind the transaction and attempt to have it declared void for the purpose of placing the property upon the tax roll. The court further stated that under sec. 70.11 (1), in respect to the state and its agencies, it was the title rather than the use which determined whether or not the property was exempt. This language was used to emphasize that some exemptions to religious and scien-[660]*660tifie bodies also require a certain use as well as ownership.
The bare legal title language was explained and somewhat eroded in State ex rel. Wisconsin University Building Corp. v. Bareis (1950), 257 Wis. 497, 44 N. W. 2d 259. In Bareis the city of Madison assessed real estate taxes on property held by the University Building Corporation, a dummy corporation of the board of regents. This court held the property was exempt from taxation. The reasoning was that although title in the real estate was in the name of the dummy corporation, it was clear the land was held for the benefit of the university and thus the beneficial owner was the state of Wisconsin. The court took a more realistic view than it did in Aberg and reasoned it would look for and make a determination of the real beneficial owner of the property claimed to be exempt from taxation. Thus the court held “owned” in the statute meant beneficial ownership, not mere technical title. In taking this view, this court stressed the substance of the transaction and not the form for the purpose of tax exemption in favor of the state.
It may be true this court has in more recent times again stressed form in dummy corporation cases to permit internal state improvements and avoid the state debt limit, but the tax exemption cases seem to be consistent in construing “owned” as meaning something substantially more in the way of enjoyment or the possession of other indicia of ownership than bare or paper title.
Aero’s contention that title equals ownership under this section is not supported by Wolf River v. Wisconsin Michigan Power Co. (1935), 217 Wis. 518, 259 N. W. 710, 98 A. L. R. 1369, and State v. Jelco (1957), 1 Wis. 2d 630, 85 N. W. 2d 487, 86 N. W. 2d 428. These cases do not equate title with ownership but support the view that beneficial ownership is the proper meaning of “owned” in tax exemption statutes. In Wolf River, the defendant, [661]*661an electric power company, conveyed 1,400 acres of land to the Valley Camp Association for the exclusive use of the Boy Scouts. The deed reserved a right of reentry for a breach and provided an option to repurchase the property. This court held the land was exempt from real estate taxes because owned by the Boy Scouts within the meaning of sec. 70.11 (36), Stats. 1933. The right of reentry and the option to repurchase were not sufficient to destroy “ownership” based upon title and actual possession.
In the Jelco Case, the state brought a suit to recover motor vehicle registration fees allegedly owed on school buses. It was provided in sec. 85.01 (4) (g), Stats. 1951, that the “owner” was to pay the fee. The school districts had been given legal title to the buses by the defendant but were required to transfer legal ownership back at the end of the school year. The buses carried a sign on them stating they were owned and operated by the school district. The school districts had a hold-harmless obligation to the defendant, carried liability insurance and had possession and control of the buses. This court held the buses were owned by the school districts, stating that the case was not one “where bare legal title was vested in school districts and all other incidents of ownership remained in the defendant.”
In the instant case the trial court in finding the hangars taxable relied on the reasoning in American Motors Corp. v. Kenosha (1957), 274 Wis. 315, 80 N. W. 2d 363, which applied the true or beneficial-ownership test for tax exemption. In the American Motors Case the corporation had entered into a contract with the United States for the manufacture and supply of aircraft engines and repair and replacement parts. The contract provided the title to all parts, materials, inventories, and work in process, should vest in the United States upon making any partial payment. The city of Kenosha assessed the personal property tax on the aircraft en[662]*662gine inventory. This court recognized that title and ownership were two different things and said the unrestricted right of the company under the contract to acquire and dispose of the property and the risk of loss were elements of ownership in American Motors Corporation inconsistent with the vesting of title in the government and the property was not owned by the federal government although legal title was transferred.
Analogous cases construing the word “owned” in other tax exempt statutes are: Armory Realty Co. v. Olsen (1933), 210 Wis. 281, 246 N. W. 513 (sec. 70.11 (16), Stats. 1929, “owned by any regiment . . . and used for . . .”); Ritchie v. Green Bay (1934), 215 Wis. 433, 254 N. W. 113, 95 A. L. R. 1081 (under land contract the property is “owned” by the vendee within the meaning of sec. 70.11 (4), Stats. 1933, exempting from taxation property “owned” by lodges); Hahn v. Walworth County (1961), 14 Wis. 2d 147, 109 N. W. 2d 653, 94 A. L. R. 2d 618 (Under trust the cestui que trust may be “owner” of property under sec. 70.11 (4), exempting from taxation property “owned” by a benevolent institution.) See also 27 Op. Atty. Gen. (1938), 551. Offutt Housing Co. v. Sarpy County (1956), 351 U. S. 253, 261, 76 Sup. Ct. 814, 100 L. Ed. 1151; Corliss v. Bowers (1930), 281 U. S. 376
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Hallows, C. J.
Aero is engaged in a noncommercial aviation business at General Mitchell Field and constructed Hangar No. 3 Addition in 1962 at its own expense on land leased from the county. It reported the building as its property for tax purposes from 1962 through 1965; Hangar No. 4 was constructed by Aero at its own expense between September 2, 1965, and April 12, 1966, also on land leased from the county. This lease is dated September 2, 1965, and it is claimed by Aero that under the terms of this lease and of a bill of sale the hangars are owned by the county within the meaning of sec. 70.11 (2), Stats.1
[659]*659The basic issues on this appeal are: (1) What is the meaning of the word “owned” in the phrase “property owned by any county” in sec. 70.11 (2), Stats.; and (2) does the lease and other facts constitute the county of Milwaukee the owner within the meaning of that section ?
We start with the conceded fact that legal title to the hangars is in the county. Aero contends the word “owned” in the section means “title” and relies principally upon Aberg v. Moe (1929), 198 Wis. 349, 224 N. W. 132, 226 N. W. 301. It is quite true in this case the court construed the word “owned” in sec. 70.11 (1), Stats., exempting state-owned property from taxation, to mean bare legal title rather than beneficial ownership. In Ah erg, a co-op conveyed land and buildings to the board of regents of the university in consideration of a lease back for a term of thirty years. The city of Madison assessed the leasehold interest to the co-op. This court, in holding the legislature had not authorized a property tax on a leasehold, stated the city of Madison had no right to go behind the transaction and attempt to have it declared void for the purpose of placing the property upon the tax roll. The court further stated that under sec. 70.11 (1), in respect to the state and its agencies, it was the title rather than the use which determined whether or not the property was exempt. This language was used to emphasize that some exemptions to religious and scien-[660]*660tifie bodies also require a certain use as well as ownership.
The bare legal title language was explained and somewhat eroded in State ex rel. Wisconsin University Building Corp. v. Bareis (1950), 257 Wis. 497, 44 N. W. 2d 259. In Bareis the city of Madison assessed real estate taxes on property held by the University Building Corporation, a dummy corporation of the board of regents. This court held the property was exempt from taxation. The reasoning was that although title in the real estate was in the name of the dummy corporation, it was clear the land was held for the benefit of the university and thus the beneficial owner was the state of Wisconsin. The court took a more realistic view than it did in Aberg and reasoned it would look for and make a determination of the real beneficial owner of the property claimed to be exempt from taxation. Thus the court held “owned” in the statute meant beneficial ownership, not mere technical title. In taking this view, this court stressed the substance of the transaction and not the form for the purpose of tax exemption in favor of the state.
It may be true this court has in more recent times again stressed form in dummy corporation cases to permit internal state improvements and avoid the state debt limit, but the tax exemption cases seem to be consistent in construing “owned” as meaning something substantially more in the way of enjoyment or the possession of other indicia of ownership than bare or paper title.
Aero’s contention that title equals ownership under this section is not supported by Wolf River v. Wisconsin Michigan Power Co. (1935), 217 Wis. 518, 259 N. W. 710, 98 A. L. R. 1369, and State v. Jelco (1957), 1 Wis. 2d 630, 85 N. W. 2d 487, 86 N. W. 2d 428. These cases do not equate title with ownership but support the view that beneficial ownership is the proper meaning of “owned” in tax exemption statutes. In Wolf River, the defendant, [661]*661an electric power company, conveyed 1,400 acres of land to the Valley Camp Association for the exclusive use of the Boy Scouts. The deed reserved a right of reentry for a breach and provided an option to repurchase the property. This court held the land was exempt from real estate taxes because owned by the Boy Scouts within the meaning of sec. 70.11 (36), Stats. 1933. The right of reentry and the option to repurchase were not sufficient to destroy “ownership” based upon title and actual possession.
In the Jelco Case, the state brought a suit to recover motor vehicle registration fees allegedly owed on school buses. It was provided in sec. 85.01 (4) (g), Stats. 1951, that the “owner” was to pay the fee. The school districts had been given legal title to the buses by the defendant but were required to transfer legal ownership back at the end of the school year. The buses carried a sign on them stating they were owned and operated by the school district. The school districts had a hold-harmless obligation to the defendant, carried liability insurance and had possession and control of the buses. This court held the buses were owned by the school districts, stating that the case was not one “where bare legal title was vested in school districts and all other incidents of ownership remained in the defendant.”
In the instant case the trial court in finding the hangars taxable relied on the reasoning in American Motors Corp. v. Kenosha (1957), 274 Wis. 315, 80 N. W. 2d 363, which applied the true or beneficial-ownership test for tax exemption. In the American Motors Case the corporation had entered into a contract with the United States for the manufacture and supply of aircraft engines and repair and replacement parts. The contract provided the title to all parts, materials, inventories, and work in process, should vest in the United States upon making any partial payment. The city of Kenosha assessed the personal property tax on the aircraft en[662]*662gine inventory. This court recognized that title and ownership were two different things and said the unrestricted right of the company under the contract to acquire and dispose of the property and the risk of loss were elements of ownership in American Motors Corporation inconsistent with the vesting of title in the government and the property was not owned by the federal government although legal title was transferred.
Analogous cases construing the word “owned” in other tax exempt statutes are: Armory Realty Co. v. Olsen (1933), 210 Wis. 281, 246 N. W. 513 (sec. 70.11 (16), Stats. 1929, “owned by any regiment . . . and used for . . .”); Ritchie v. Green Bay (1934), 215 Wis. 433, 254 N. W. 113, 95 A. L. R. 1081 (under land contract the property is “owned” by the vendee within the meaning of sec. 70.11 (4), Stats. 1933, exempting from taxation property “owned” by lodges); Hahn v. Walworth County (1961), 14 Wis. 2d 147, 109 N. W. 2d 653, 94 A. L. R. 2d 618 (Under trust the cestui que trust may be “owner” of property under sec. 70.11 (4), exempting from taxation property “owned” by a benevolent institution.) See also 27 Op. Atty. Gen. (1938), 551. Offutt Housing Co. v. Sarpy County (1956), 351 U. S. 253, 261, 76 Sup. Ct. 814, 100 L. Ed. 1151; Corliss v. Bowers (1930), 281 U. S. 376, 378, 50 Sup. Ct. 336, 74 L. Ed. 916.
We think the ownership of property by a municipality to qualify for exemption under sec. 70.11 (2), Stats., means real or true ownership and not paper title only. Ownership is often referred to in legal philosophy as a bundle of sticks or rights and one or more of the sticks may be separated from the bundle and the bundle will still be considered ownership. What combination of rights less than the whole bundle will constitute ownership is a question which must be determined in each case in the context of the purpose of the determination. In this case for exemption one needs more than the title stick to constitute ownership.
[663]*663The trial court examined the lease in the light of the facts and concluded that Aero had sufficient ownership to sustain the taxation of the hangars. We agree. The lease of September 2, 1965, provided the county would lease certain lands and other buildings at Mitchell Field to Aero for a term of twenty years with an option to renew for five years. Aero was required to pay rent for the land and these buildings but no rent was to be paid for Hangar No. 3 Addition and for Hangar No. 4 which was to be built. In the event that Aero exercised its five-year option, no rent was to be paid for Hangar No. 4, but rent based on square footage of floor space would be paid for Hangar No. 3 Addition.
Paragraph 11 of the lease provided that the lessee should have a right to construct Hangar No. 4 and in paragraph 13 upon its completion the title thereto would immediately vest in the county “without compensation to Lessee or any consideration other than the leasehold rights granted hereby, and the Lessee shall not have the right to remove same upon termination of this lease.” There were other provisions, i.e., that the lessee could make no alterations without prior consent of the lessor; if such alterations were made they should be made without cost to the lessor; and upon their completion would become the property of the lessor.
In respect to Hangar No. 3 Addition the lessee by paragraph 30 agreed to convey to the lessor the title at no cost to the lessor and free and clear of all encumbrances. By paragraphs 20 and 33 (a), Aero was responsible at its own costs for the repair and the upkeep of the hangars including all structural elements. However, as to other buildings under the lease, the maintenance of other structural elements was assumed by the county. In paragraph 32 (f) of the lease Aero was required to procure fire and extended insurance coverage for Hangar No. 4 to the extent of 80 percent of the insurable value. Lessee was obligated to use any sums received in settle[664]*664ment of claims to the immediate repair of any damage to the hangar.
In another part of the lease all costs incurred by the lessee in repair and upkeep of any building following damage by fire, explosion or windstorm, or other cause, were not reimbursable by the lessee in the event of condemnation. The lease is silent on who pays for the repairs in the event of fire if the insurance proceeds received by the lessee are not sufficient to make such repairs. The compulsory standard fire policy in Wisconsin, ch. 203, Stats., insures only to the extent of the insured’s interest; consequently, the intent of the parties to the lease must have been that the lessee had a substantial insurable interest in the hangars since it was required to insure up to 80 percent of the insurable value.
Paragraphs 35 and 38 provided that in the event the county condemned the leased land or if the airport was abandoned as an air terminal or the lessor breached a provision of the lease so as to terminate it, the lessor shall “as full compensation for such transfer of title, pay to Lessee a sum of money equal to Lessee’s unamortized investment in the improvements constructed by Lessee on said leased premises and existing at the date of the taking, computed on the basis of Lessee’s investment cost . . . less five per cent (5%) of such sum for each year subsequent to the date of the completion of the construction of such improvements . . .” This provision of the lease assures to the lessee under these conditions its investment cost of the hangars on an amortized basis if it does not enjoy the possession and use of the buildings for the full term of the lease. It is stipulated the lessee amortizes its cost of construction of the hangars as leasehold improvements over the term of the lease for both state and federal income-tax purposes. If the land is condemned by the United States or the state of Wisconsin during the term of the lease, Aero’s only claim is against such government.
[665]*665Under this lease arrangement, some of the rights usually associated with ownership are in Aero and others are in the county. The lease bears a striking resemblance to the Aberg lease, but the holding in that case has been shaken by more recent decisions. This arrangement does not constitute a conventional conveyance and leaseback and there are several provisions in the lease inconsistent with or certainly unusual in a conventional lease of land and buildings. Such control the county keeps over these hangars is not indicative of true ownership but concerns the operation of the airport. We cannot view this arrangement as a bona fide conveyance of the buildings, the cost of which is treated as prepaid rent. It does not purport to be that. This is a hybrid arrangement, possibly to obtain both a tax exemption and the amortization of the cost of the buildings over a relatively short period of twenty years.
On weighing all considerations, this arrangement does not pass sufficient incidents of ownership with the paper title to constitute the county the true owner of the hangars within the meaning of “owned” in sec. 70.11 (2), Stats.
By the Court. — Judgment affirmed.