In John Tennant Memorial Homes, Inc. v. City of Pacific Grove (1972) 27 Cal. App. 3d 372, the court could find no rational basis for imposing a tax on persons living in nonprofit retirement homes and persons living in for-profit retirement homes. The stated justification for the tax was that persons living in retirement homes required special protections because of their advance age. That justification, however, applied equally to nonprofit homes and privately owned homes. (John Tennant Memorial Homes, Inc. v. City of Pacific Grove, supra, 27 Cal. App. 3d at p. 379.) The court also rejected the city's claim that the distinction was justified on the theory that the nonprofit homes did not pay municipal property tax, pointing out that the fact that nonprofit homes paid no tax could not justify a tax on the occupants of those homes when the occupants of private homes were not taxed. (Id. at pp. 380-381.)