TRENTON - The state may force up to 158 school districts across New Jersey to reduce property taxes in return for millions in new education money.

Though Gov. Corzine proposes to boost state education aid by $530 million next year, his administration has decided that many of the state's 618 school districts spend more than enough to provide a decent education.

Under a little-noticed provision in his new funding plan, such districts - including up to 27 middle-class districts in South Jersey - could be required next year to reduce property taxes, most of which go to fund school systems.

Lucille E. Davy, Corzine's education commissioner, said yesterday that with New Jersey providing "significant additional aid" to public schools, "some of that has got to be used to relieve the taxpayers."

The Corzine administration had mentioned the tax-cut provision as one aspect among many ingredients of the new education-funding formula it rolled out last week.

But the full scope of the tax-relief requirement did not become clear until yesterday, when Davy released the 106-page text of the formula bill.

As if they were watching money go up in smoke, some education groups were left stunned.

"This is a totally different picture than was presented," said Frank Belluscio 3d, a veteran lobbyist here with the New Jersey School Boards Association. "Last week, we looked [at Corzine's proposal] and said we were optimistic. This totally wipes that out."

Still, the tax-relief proposal might win political support in a state groaning under a property-tax burden that surveys say is the highest in America.

Corzine's $530 million increase in state aid would boost state education funding by 7 percent, up to $7.8 billion.

Under his plan, every district would get an increase in money, ranging from 2 percent to 20 percent.

Despite demands from opponents that Corzine slow down, he and his fellow Democrats, who control the Legislature, are pushing to adopt the funding plan before the close of the current lame-duck session on Jan. 8.

While 158 districts might see tax cuts, Davy also disclosed yesterday that the plan also could force about 10 urban districts in the state to increase taxes.

They are among the 31 "Abbott" systems - high-poverty, big-enrollment districts that have long been targeted for special state help under court order. Davy said that analysis has shown that several of these communities were not taxing local residents as heavily as they should, compared with the burden imposed by other communities.

Davy said she could not immediately name the districts being considered for either tax hikes or cuts.

She said that the choice would be made district by district. No district, she noted, would be permitted to cut taxes deeply enough to provide less than that community's "fair-share" burden for education.

An analysis by The Inquirer found that 158 districts statewide might face tax reductions.

The analysis showed that of the 108 school districts in Burlington, Camden and Gloucester Counties, 27 could be subject to the tax-relief requirement.

Under Davy's leadership, the state Education Department spent months costing out what its experts believe is the amount that must be spent per child to provide a decent education in New Jersey.

The goal was to arrive at a figure that would meet the state constitution's requirement that all youngsters get a "thorough and efficient" education.

Some critics have said the process improperly "low-balled" the amount of money needed, a complaint that Davy vigorously rejected yesterday.

At any rate, with that number in hand, the state was able to predict how many districts would be spending in excess of the required minimum next year, once additional state aid arrived.

Such districts were said by the administration to be exceeding educational "adequacy."

School-finance expert Deborah Yaffe, author of Other People's Children: The Battle for Justice and Equality in New Jersey's Schools, said the Corzine proposal would likely stir up strong political opposition in the state's middle-class and wealthier communities.

Depending on the mechanics of how the state would force the tax cut, she said, residents may still feel pressure to raise money locally to improve schools.

She said that by directing state aid toward tax relief, Corzine and his aides were saying, "If you want to spend above adequacy, you're going to have to raise it yourself."

In all, about 400 of the state's 618 districts were forecast to be spending above adequacy, according to statistics released by the administration last week.

Under Corzine's funding proposal, such districts would be permitted to keep a 2 percent hike in state aid for educational purposes. But any increase above that would have to go to tax relief.

The Inquirer identified the 27 school districts in the three South Jersey counties nearest Philadelphia that were to get increases above 2 percent and thus might be subject to the tax-relief rule.

As an example, the Corzine administration said that property taxes and state aid combined would give Medford Township, in Burlington County, 15 percent more next year than was needed to provide an adequate education.

The administration said last week that Medford was in line for a 9 percent increase in state education aid under its new formula.

However, the tax-cut provision could mean the schools would only see a 2 percent increase for school aid - and that the remaining money would go to roll back taxes.

In a Camden County example, the administration said that the Cherry Hill School District would spend 14 percent more than was absolutely necessary.

So, while the plan announced last week called for a 10 percent increase in state education aid to Cherry Hill, the real increase might turn out to be 2 percent, with the remainder going to tax relief.

Only one district would be affected in Gloucester County, according to the Inquirer analysis. That would be the Glassboro school system, which the state forecast said would spend 7 percent more than was needed for "adequacy."

As a result, while it is in line for a 10 percent increase in aid, its actual increase could be limited to 2 percent for educational purposes, with the rest going to tax relief.

When districts were ranked overall, the state's data showed that a cluster of Shore towns - presumably flush with tax revenue from vacation-property owners who send their children to school elsewhere - spent the most generously on education.

The ranking showed that the Allenhurst school system north of Asbury Park spent almost 10 times per child what the state said was the base "adequacy" amount.

Inland, it found that the highly affluent Alpine District, in Bergen County, spent almost twice as much as the minimum requirement. Alpine, home of comedian Eddie Murphy, is the seventh-most-affluent zip code in the United States.

Among South Jersey communities, the state's ranking found that Washington Township, in Burlington County, exceeded the minimum by the highest margin. Its spending was deemed to be 62 percent above the "adequacy" level.

However, Corzine is seeking only a 2 percent hike in state aid in Washington Township, so its residents would not be in line for any tax relief.

Contact staff writer Craig R. McCoy at 609-989-9016 or cmccoy@phillynews.com.