In Britt v. City of Pomona (1990) 223 Cal. App. 3d 265, the court could discern no rational basis for imposing a tax on persons living in hotels and like lodgings, but not on persons living in other types of housing such as apartments, houses and boarding homes. The court also criticized the tax for distinguishing between persons living in hotels under a tenancy contract and persons living in hotels on a day-to-day basis. It could find no valid distinction between classifications from the standpoint of the persons required to pay the tax, whose basic needs were the same as those of persons living in more traditional forms of housing and who did not have to pay the taxes. (Id. at p. 277.) The city argued that a rational basis for the tax existed because it helped pay for persons residing within its boundaries. The court pointed out, however, that "those same services are provided to all persons who occupy housing not owned by them, whether they live in transient-type housing or not. Yet, the tax is imposed on only a portion of those persons and therefore does not treat similarly situated persons equally." (Id. at pp. 277-278.) Finally, the court rejected a second rationale offered by the city--discouraging long-term occupancy of transient type accommodations because of health and safety problems--pointing out that hotel residents having a tenancy arrangement with the owner would not be required to pay the tax. In addition, the law did not prohibit persons from residing in hotels for extended periods of time. "Clearly, anyone with the financial ability to pay the tax can continue to reside in a 'hotel' indefinitely." (Id. at p. 278.) In Britt v. City of Pomona, the City of Pomona used the term "dwelling" in the definition of "hotel," thus making it appear that permanent residents also had to pay the tax. Significantly, however, the definitions of the terms "hotel," "occupancy," and "transient" did not confine the tax to those occupying a hotel for any specific period. The contested ordinances were the result of amendments that had eliminated the city's previous limitation of the occupancy period. Before the 1987 and 1988 amendments the ordinance had defined "transient" as a person who occupied a lodging for a period of 30 days or less. ( Britt v. City of Pomona, supra, 223 Cal. App. 3d at p. 270.) Thus, it was readily susceptible of an interpretation that a person "dwelling" in the hotel on a long-term basis was subject to the tax. ( Britt v. City of Pomona, supra, 223 Cal. App. 3d at p. 279.)