In City of Livermore v. Pacific Gas & Electric Co. (1981) 120 Cal. App. 3d 1001, PG&E was subjected to taxes comparable to those imposed on a variety of businesses, including water companies, wholesale and retail sellers, manufacturers, other utility companies and most other businesses. Grocers and automotive dealers, however, were charged a lower rate. PG&E argued, in essence, that under California Constitution, article XIII, section 19, it could be taxed at a rate no greater than the lowest tax rate imposed on any mercantile, manufacturing or other business corporation. In rejecting this argument, the court held: "We do not read the section so narrowly as to prohibit the imposition of a lower tax rate on other businesses within the community where a rational basis therefor is demonstrated by the taxing authority. The history of section 19 and its predecessor former section 14 . . . prohibits municipalities from unfairly extracting excessive taxes from utilities by requiring that they be taxed in conformity with taxes imposed upon other businesses. Here all mercantile, manufacturing, and business corporations are taxed at the same or higher rate as P.G. & E., except two types of businesses, grocers and automobile dealers. The record indicates that the license tax was directed at taxing the profits of all businesses at a uniform rate and that the city found those two businesses to have significantly lower profit margins, thereby necessitating, in fairness, a rate differential.No contention is made that P.G. & E. is a similar low profit margin business. It is not in fact being subjected to a different or greater tax as there is a demonstrated rational basis for the imposition of a lesser tax rate upon grocers and automobile dealers. Therefore, P.G. & E. is in fact not being taxed differently from other mercantile, manufacturing, and other business corporations within Livermore." (City of Livermore v. Pacific Gas & Electric Co., supra, 120 Cal. App. 3d at pp. 1005-1006.)