In Resolution Trust Corp. v. Lanzaro, 140 N.J. 244, 658 A.2d 282 (1995) the Court had held that the RTC was required to pay the "fee" on the basis that it was not a "tax" because the reasonableness of the assessment could not be "properly determined . . . by a single transaction but rather by the overall statutory scheme, which is designed to provide for the self-support of this function of the Sheriff's office." 271 N.J. Super. 189, 191, 638 A.2d 812 (App.Div.1994), rev'd, 140 N.J. 244, 658 A.2d 282 (1995). The Court concluded that the "reasonableness may be evaluated in terms of the benefit conferred upon the person required to pay as well as in terms of the expense to the sheriff in providing the service." Id. at 191-92, 638 A.2d 812. In reversing the judgment, the Supreme Court rejected this thesis. 140 N.J. at 258-60, 658 A.2d 282. According to Justice Stein: Nor is the revenue-raising characteristic of the Sheriff's fee diminished by the statistics, emphasized by the lower courts, demonstrating that the annual amount of the fees collected by the Sheriff and remitted to the County defray a substantial portion of the cost of operating the Sheriff's office. That the Sheriff's fees are substantial enough to offset approximately one-third of the budgeted costs of operating his office may well substantiate the soundness of the fee schedule as a matter of legislative policy. But the success of the fee schedule as a revenue source cannot justify imposition of the fee on an entity that Congress has declared to be totally exempt from such exactions. Id. at 259-60, 658 A.2d 282. Although the issue involved in Resolution Trust concerned the federal exemption from payment of a tax, that case does not change the essence of the Supreme Court's analysis that the fee under N.J.S.A. 22A:4-8, even though used to help defray the cost of operating the Sheriff's office or commensurate to the benefit received by plaintiff, was nonetheless a tax because of the "disproportion between the charge and the cost of the service." Id. at 259, 658 A.2d 282.