The Act is consonant with this constitutional mandate in that nothing in the Act indicates an intention by the Legislature to require application of the LOST revenue so as to gratuitously reduce the millage rate applied to residents outside the special district. The trial court's reliance upon Nielubowicz v. Chatham County, 252 Ga. 330 ( 312 S.E.2d 802) (1984) and Martin v. Ellis, 242 Ga. 340 ( 249 S.E.2d 23) (1978) is misplaced. In Nielubowicz, we rejected the argument that the revenue produced by the Act applies only to unincorporated areas of the special district and found that it was applicable to all tangible property within the special district.
See City Council of Augusta v. Mangelly, 243 Ga. 358, 362 (1) ( 254 S.E.2d 315) (1979) ("[I]t can never be a valid county purpose to provide [its tax] revenue to a municipality, because municipalities are not citizens of nor creatures of counties — they are an entirely different form of government."), superseded by statute on other grounds as noted in Nielubowicz v. Chatham County, 252 Ga. 330, 330 fn. 1 ( 312 S.E.2d 802) (1984). If the legislature had intended for counties to share HOST sales and use tax proceeds with cities in the manner described in the Intergovernmental Agreement, it could have so stated.
We must not, however, "give to the statute an effect altogether different from that sought by it when considered as a whole." City Council of Augusta v. Mangelly, 243 Ga. 358, 254 S.E.2d 315, 320 (1979) (Hill, J., dissenting) (superseded by statute as noted in Nielubowicz v. Chatham County, 252 Ga. 330, 312 S.E.2d 802, 803 n. 1 (1984)). Accordingly, under Georgia law, we must determine whether the invalid provisions of the Adult Ordinance are mutually dependent upon any other portions of the Adult Ordinance, while at the same time preserving the original purpose of the ordinance.