Mr. Chief Justice Stone
delivered the opinion of the Court.
An Arkansas statute, 'Act 118 of 1923, Pope’s Digest, Arkansas Statutes (1937), § 13371, imposes “a privilege or license tax . . . upon each person . . . engaged in the business of . . . severing from the soil . . . for commercial purposes natural resources, including . . . timber ...” ■By § 13372, as a condition of the license, there is imposéd on the severer an obligation to pay the tax and consent that the tax “shall . . . remain a lien on each unit of production until paid into.the State Treasury . . .” Section 13375 fixes the tax at 7 cents per thousand feet of the tim- • ber severed. Section 13376 provides that the state “shall have a lien upon any and all natural resources severed from the soil . . .” In § 13382 it is provided that “the payment of said privilege taxes shall be required of the severer . . . actually engaged in the operation of severing natural products whether as owner, lessee, concessionaire or contractor. The reporting taxpayer shall collect or withhold out of the proceeds of the sale of the products severed the proportionate parts of the total tax due by the [478]*478respective owners of such natural resources at the time of severance.”
Appellants in No. 328, a copartnership, entered into contracts with the United States for the purchase and severance of timber on national forest reserves located within the state, some of which were public lands of the United States when Arkansas was admitted to statehood and some of which were acquired by the United States by purchase with the consent of the state. The contracts of severance and purchase provided that “title to all timber included in this agreement shall remain in' the United States until it has been paid for, and sealed, measured or counted.” By the contracts the appellants were required in advance of severance to place with the Government /representative advance installments of the estimated ¡purchase price.
In the years 1937 to 1942, appellants, proceeding under their contract, severed'timber from the forest reserves in question. An execution having been issued and delivered to the county sheriff, appellee in No. 328, and also appellant in No. 329, for collection of the tax assessed against appellants in No. 328 for the years in question, they brought the present suit in the state chancery court to enjoin the collection. The questions on which the parties ask decision are (a) whether the forest reserves which' were public lands of the United States before Arkansas was admitted to statehood are subject to the taxing jurisdiction of the state; (b) whether the forest reserves acquired by the United States by purchase remain subject to the taxing authority of the state; and (c) whether the.'tax is unconstitutional as a tax laid upon the property or activities of the' United States, or because the tax laid on plaintiffs imposed an unconstitutional burden on the United States.
The chancery court gave judgment for plaintiffs, enjoining collection of the tax. It held that if the tax “be [479]*479applied” to plaintiffs, it “would be a tax upon the operations of the Government of the United States,” and that the tax “does not apply to the timber severed by the plaintiffs from the National Forest.” On appeal the Supreme Court of Arkansas modified the judgment, holding that the state was without authority to lay a tax on the severance of timber from lands which were public lands of the United States when Arkansas was admitted to statehood; that the authority of the state to lay the tax extended to transactions occurring on the forest reserve acquired by the United States by purchase; and that the present tax assessed against plaintiffs for the severance of timber on forest reserves of this class did not lay an unconstitutional burden on the United States. 208 Ark. 459, 187 S. W. 2d 7.
Plaintiffs have appealed, in No. 328, from so much of the judgment as sustained the tax with respect to lands acquired by the United States by purchase, urging in their assignments of error that the Supreme Court of Arkansas erred in reversing the judgment of the chancery court, “which held to be void the severance tax statute,” and in holding that the severance tax law is not repugnant to the supremacy clause, Art. VI, cl. 2 of the Constitution, or to Art. IV, § 3, cl. 2, conferring on Congress power to dispose of “and make all needful Rules and Regulations respecting . . . Property belonging to the United States . . .” Defendant, appellant in No. 329, seeks by his appeal to reverse so much of the judgment as denied the right to levy the tax for severance of timber from forest lands reserved from the public domain. On submission of the jurisdictional statements in this Court we postponed to the hearing on the merits consideration of our jurisdiction in No. 328. In No. 329 we dismissed the appeal for want of jurisdiction. § 237 (a) of the Judicial Code as amended, 28 U. S. C. § 344 (a). Treating the papers on which the ap[480]*480peal was allowed as a petition for writ of certiorari, as required by § 237 (c) of the Judicial Code as amended, we granted certiorari.
Under § 237 of the Judicial Code we are without jurisdiction of the appeal in No. 328, unless there was “drawn in question” before the Supreme Court of Arkansas “the validity of a statute” of the state, “on the ground of its being repugnant to the Constitution, ... or laws of the United States.” The purpose of this requirement is to restrict our mandatory jurisdiction on appeal, Memphis Gas Co. v. Beeler, 315 U. S. 649, 651, and to make certain that no judgment of a state court will be reviewed on appeal by this Court unless the highest court of the state has first been apprised that a state statute is being assailed as invalid on federal grounds, Charleston Assn. v. Alderson, 324 U. S. 182, 185-6 and cases cited, of, when the statute, as applied, is so assailed, until it has opportunity authoritatively to construe it. Fiske v. Kansas, 274 U. S. 380, 385 and cases cited. This jurisdictional requirement is satisr fied only if the record shows that the question of the validity under federal law of the state statute, as construed and applied, has either been presented for decision to the highest court of the state, Wall v. Chesapeake & Ohio R. Co., 256 U. S. 125, 126; Citizens National Bank v. Durr, 257 U. S. 99, 106, or has in fact been decided by it, Nickey v. Mississippi, 292 U. S. 393, 394; Whitfield v. Ohio, 297 U. S. 431, 435-6, and that its decision was necessary to the judgment. Cuyahoga Power Co. v. Northern Realty Co., 244 U. S. 300, 304 and cases cited. The record in this case does not disclose that at any time in the course of the proceedings in the state courts pláintiffs asserted the invalidity of a state statute on any federal ground. The bill of complaint, in the chancery court set up only that the demand of the staté for the tax “is an illegal and void exaction” and “is in violation of ” Art. IV, § 3, cl. 2 and of Art. [481]*481VI, cl. 2 of the Constitution. There were no assignments of error in the Supreme Court of Arkansas.
As the record does not show that the plaintiffs presented for decision to the state Supreme Court any federal question, they have no appeal to this Court unless the opinion of the state Supreme Court shows that that court ruled on the validity of a state statute under the laws and Constitution of the United States. Charleston Assn. v. Alderson, supra, 185-6 and cases cited. That court’s opinion, while holding that the “tax law” was applicable to “persons severing timber from lands of the United States in a national forest,” does not indicate that plaintiffs raised there, or that the court passed upon, the validity of the statute as applied. The court considered only the validity of “the tax,” not that of the statute.
With reference to plaintiffs’ liability for the tax, it decided only that the state “has the right to collect the •severance tax, so far as territorial jurisdiction is concerned,” for severance of timber from lands acquired by the United States by purchase, and that plaintiffs could not claim the benefits of the immunity, if any, of the Federal Government from “the tax,” since it was imposed on plaintiffs, not the Government pr its property. It said that the Government was not constitutionally immune from such economic burden as might be passed on from the taxpayer to the Government by reason of the effect of the tax paid by the severers, citing James v. Dravo Contracting Co., 302 U. S. 134 and Alabama v. King & Boozer, 314 U. S. 1. Being asked to enjoin the collection of the tax, the state court contented itself with holding that the tax, which was assessed on plaintiffs and not the Government, imposed no burden on the Government which infringed its implied constitutional tax immunity. Since the'collection of a tax by a state officer, as here, may or may not offend against the Constitution, independently of the [482]*482constitutionality of a statute, see Nashville, C. & St. L. R. Co. v. Browning, 310 U. S. 362, 369, the state court, in holding the tax constitutional, did not necessarily pass on the constitutional validity of the statute.
In order to support an appeal to this Court it is necessary that the question of the validity of the state taxing statute be either presented to the state court or decided by it. It is not sufficient merely to attack, as here, the tax levied under the statute, or “the right to collect the tax” which has been levied, or to show that the validity of the tax alone has been considered. Charleston Assn. v. Alder-son, supra, 185, and cases cited. For “the mere objection to an exercise of authority under a statute, whose validity is not attacked, cannot be made the basis”, of an appeal. Jett Bros. Co. v. City of Carrollton, 252 U. S. 1, 6. It is for this reason that we have held that an appeal will not be sustained where there has been only an attack upon a tax assessment, Jett Bros. Co. v. City of Carrollton, supra; Miller v. Board of County Comm’rs, 290 U. S. 586; Memphis Gas Co. v. Beeler, supra, 650; Commercial Credit Co. v. O’Brien, 323 U. S. 665; Charleston Assn. v. Alderson, supra, 185, or, as here, upon a “tax,” Citizens National Bank v. Durr, supra, 106; Indian Territory Illuminating Co. v. Board of County Comm’rs, 287 U. S. 573; Baltimore National Bank v. State Tax Comm’n, 296 U. S. 538; Irvine v. Spaeth, 314 U. S. 575, or upon the attempt to collect a tax, Jett Bros. Co. v. City of Carrollton, supra.
Since plaintiffs’ attack'is directed to the validity of the tax as laid, and not to the validity of the statute, as applied, we are without jurisdiction of their appeal under § 237 of the Judicial Code. Treating the appeal as a petition fc..- writ of certiorari, as reqpired by § 237 (c) of the Judicial Code, we grant certiorari, as we did in No. 329. We can consider only the federal questions passed upon by the state Supreme Court.
Our decision in James v. Dravo Contracting Co., supra, and in Alabama v. King & Boozer, supra, and the cases [483]*483cited in those opinions, can leave no doubt that the Supreme Court of Arkansas correctly held that plaintiffs, who are taxed by the state on their activities in severing lumber from Government lands under contract with the Government, cannot claim the benefit of the implied constitutional immunity of the Federal Government from taxation by the state.
Plaintiffs now, for the first time, assail the tax and the statute imposing it, on the ground that the Act requires the severer to collect the tax from the owner of the timber at the time of severance, Pope’s Digest, § 13382, and gives to the state a lien on the land from which the lumber is severed, id., § 13374, and a lien upon the severed timber, id., § 13376, even though title to the severed product has not passed to the taxpayer. They contend that the Act thus purports to place a forbidden tax directly on the United States. Cf. Mayo v. United States, 319 U. S. 441.
But we are not free to consider these grounds of attack for the reason that they were not presented to the Supreme Court of Arkansas or considered or decided by it. While the constitutional question now sought to be presented is in some measure related to that decided by the state court, and, like it, arises under the implied constitutional immunity of the Federal Government from state taxation, it is not merely “an enlargement” of an argument made before the state court, but is so distinct from the question decided by the state court that our decision of the issue raised there would not necessarily decide that now sought to be raised. Compare Dewey v. Des Moines, 173 U. S. 193, 197, 198. We are therefore not free to consider it.
“In reviewing the judgment of a state court, this Court will not pass upon any federal question not shown by the record to have been raised in the state court or considered there, whether it be one arising under a different or the' same clause in the Constitution with respect to which other questions are properly presented.” New York ex rel. Cohn [484]*484v. Graves, 300 U. S. 308, 317, and cases cited. For, as we said in McGoldrick v. Compagnie Generale, 309 U. S. 430, 434-435, “In cases coming here from state courts in which a state statute is assailed as unconstitutional, there are reasons of peculiar force which should lead us to refrain from deciding questions not presented or decided in the highest court of the state whose judicial action we are called upon to review. Apart from the reluctance with which every court should proceed to set aside legislation as unconstitutional on grounds not properly presented, due regard for the appropriate relationship of this Court to state courts requires us to decline to consider and decide questions affecting the validity of state statutes not urged or considered there. It is for these reasons that this Court, where the constitutionality of a statute has been upheld in the state court, consistently refuses to consider any grounds of attack not raised or decided in that court.” See also Keokuk & Hamilton Bridge Co. v. Illinois, 175 U. S. 626, 633; Bolln v. Nebraska, 176 U. S. 83, 89-92; New York v. Kleinert, 268 U. S. 646, 650-1; Whitney v. California, 274 U. S. 357; 362, 363; Saltonstall v. Saltonstall, 276 U. S. 260, 267-8.
In view of the lien provisions of the statute and its provisions which purport to authorize the taxpayer to collect the tax from the owner of the severed timber, here the Government, it is suggested that we cannot rightly adjudge that the state is entitled to recover the tax on the transactions of severance involved, without determining the applicability of these provisions to the Government and their validity if so applied. We are not now concerned with the Government’s liability to the statutory lien or for payment of the tax. It will be time enough to consider its interests when some effort is made to enforce the lien or collect the tax from the United States. We obviously do not by our judgment against the plaintiffs [485]*485impose the tax on the Government. Their property alone is subject to the lien of the present judgment and to execution issued under it. They cannot recover the amount of the judgment from the Government unless the Constitution permits. And if it forbids they obviously will not collect the tax. In neither case does our judgment impose any burden on the United States. We are not called on to determine whether plaintiffs could have successfully contested their liability in the state courts or here, if the contentions were properly raised, upon the ground that they would be unable to collect the tax from the Government, either because the provision purporting to allow such collection is inapplicable where the owner is the Government or, if applicable, invalid, or on the ground that the tax, applied to them without recourse against the Government, would deny to them the equal protection of the laws.
The state, construing its own law, has rendered an unconditional judgment holding plaintiffs liable for the tax. For purposes of our review we must assume that the judgment conforms to state law. Hence we are called on to determine only federal questions properly raised on the record. Considering the only question of the tax immunity of the United States which is so raised, we decide for reasons already stated that the tax now laid and sustained imposes no unconstitutional burden on the Federal Government. No question arising under the Fourteenth Amendment is raised by the record either in the state courts or here, and we are without jurisdiction to pass upon it.
[486]*486A further question is whether the lands in the forest reserve, which were purchased for that purpose by the United States, are within the territorial taxing jurisdiction of the state. The answer turns on the interpretation of the statute of the United States authorizing the acquisition of the lands, §§ 7 and 12 of the Act of March 1,1911, c. 186,36 Stat. 961,16 U. S. C. §§ 480,516, and of the state statute of Arkansas authorizing the sale. Pope’s Digest, § 5646. The meaning of both statutes, as applied in this case, is a federal question, since upon their construction depend rights, powers and duties of the United States. Mason Co. v. Tax Comm’n, 302 U. S. 186, 197, and cases cited.
The statute of Arkansas consenting to the purchase of forest lands by the United States, provided that the state should “retain a concurrent jurisdiction with the United States in and over lands so acquired . . .,” to issue and execute “civil process in all cases, and such criminal process as may issue under the authority of the State . . .” It made no express grant, or reservation of legislative power over the areas purchased. Hence the statute cannot be taken as having yielded or intended to surrender to the Federal Government the state legislative jurisdiction over the area in question, so far as exercise of that jurisdiction is consistent with federal functions. Any doubt as to the effect of such a grant by the state in conferring exclusive legislative jurisdiction over the territory which is acquired by the Federal Government is removed by the provisions of the federal statute.
Section 12 of the federal statute, authorizing the pur- ■ chase, provided:
“That the jurisdiction, both civil and criminal, over" persons upon the lands acquired under this Act shall not be affected or changed by their permanent reservation . . . as national forest lands, except so far as [487]*487the punishment of offenses against the United States is concerned, the intent and meaning of this section being that the State wherein such land is situated shall not, by reason of such reservation and administration,lose its jurisdiction nor the inhabitants thereof their rights and privileges as citizens or be absolved from their duties as citizens of the State.”
By this enactment Congress in effect has declined to accept exclusive legislative jurisdiction over forest reserve lands, and expressly provided that the state shall not lose its jurisdiction in this respect nor the inhabitants “be absolved from their duties as citizens of the State.” Compare Mason Co. v. Tax Comm’n, supra; Atkinson v. Tax Comm’n, 303 U. S. 20; Collins v. Yosemite Park Co., 304 U. S. 518, 528; Stewart & Co. v. Sadrakula, 309 U. S. 94, 99.
Our conclusion, based on the construction of the interrelated state and federal statutes, is that the state has territorial jurisdiction to lay the tax upon activities carried on within the forest reserve purchased by the United States. .
What we have said of the argument that the tax assessed on plaintiffs is an unconstitutional burden on the Government, is applicable to the tax assessed for severance of timber from forest reserve lands which, from the beginning, have been a part of the public domain. That tax is likewise valid if the state has legislative jurisdiction over such lands within its boundaries.
Upon admission of Arkansas to statehood in 1836 upon an equal footing with the original states (Act of June 15, 1836, c. 100, 5 Stat. 50), the legislative authority of the state extended over the federally owned lands within the state, to the same extent as over similar property held by private owners, save that the state could enact no law which would conflict with the powers reserved to the United States by the Constitution Ft. Leavenworth R. [488]*488Co. v. Lowe, 114 U. S. 525, 539; Utah Power & Light Co. v. United States, 243 U. S. 389, 404. Such authority did not pass to the United States by virtue of the provisions of Article I, § 8, cl. 17 of the Constitution, which authorize it “to exercise exclusive Legislation . . . over all Places purchased by the Consent of the Legislature of the State in which the Same shall be.” .
Since the United States did not purchase the lands with the consent of the state, it did not acquire exclusive jurisdiction under the constitutional provision, and there has been no cession of jurisdiction by the state. Surplus Trading Co. v. Cook, 281 U. S. 647, 651; Mason Co. v. Tax Comm’n, supra, 210. Although Arkansas has, by § 5647, Pope’s Digest, conferred on Congress power to pass, laws, civil and criminal, for the administration and control of lands acquired by the United States in Arkansas, it has ceded exclusive legislative jurisdiction neither over lands reserved by the United States from the public domain nor over lands acquired in the state. Ft. Leavenworth R. Co. v. Lowe, supra, 530, 531. It follows that the state has retained its legislative jurisdiction, which it acquired by statehood, over public lands within the state, which have been included within the forest reserve.
We conclude that the state has legislative jurisdiction over the federal forest reserve lands located within it, whether they were originally a part of the public domain of the United States, or were acquired by the United States by purchase, and that the tax assessed against plaintiffs is not subject to any constitutional infirmity, or to any want of taxing jurisdiction of the state to lay it with respect to transactions on the federal forest reserve located within the state.
The judgment is reversed insofar as it adjudged plaintiffs not liable for the tax on severance of timber from lands held by the United States as original owner, and the cause [489]*489is remanded to the Supreme Court of Arkansas for further proceedings not inconsistent with this opinion. In all other respects the judgment is affirmed. On the remand the state courts will be free, so far as their own practice allows, to determine any state questions here involved and any federal questions not already decided by this opinion. Compare Schuylkill Trust Co. v. Pennsylvania, 302 U. S. 506, with Schuylkill Trust Co. v. Pennsylvania, 296 U. S. 113.
So ordered.
Me. Justice Douglas concurs in the result.
Me. Justice Jackson took no part in the consideration or decision of these cases.
Even if the opinion of the Supreme Court of Arkansas had proceeded on a ground so unexpected as to make timely, by petition for rehearing, the raising of the federal questions now for the first time advanced, compare Saunders v. Shaw, 244 U. S. 317; Ohio v. Akron Park District, 281 U. S. 74, 79, plaintiffs in their petition for rehearing did not suggest them.