In San Francisco v. County of Alameda (1936) 5 Cal.2d 243 (CCSF), the question was whether a county could continue to collect property taxes on water rights a city in another county had purchased from a water company, which had itself acquired them by purchase or condemnation from riparian owners in the taxing county. The city asserted that the rights were governed by the general rule exempting public property from taxation. (Cal. Const., art. XIII, former 1, repealed Nov. 5, 1974; see Cal. Const., art. XIII, 3.) The county argued that they fell under a 1914 constitutional amendment permitting the taxation of "lands and ... improvements" owned by a local public entity outside the taxing county's borders, provided the rights were subject to taxation when the entity acquired them. (Cal. Const., art. XIII, former 1, repealed Nov. 5, 1974; see Cal. Const., art. XIII, 11.) The dispositive question, wrote the court, was "whether the water rights acquired by the city by purchase from the ... water company were included within the term 'land' as used in the constitutional amendment and as such therefore separately assessable in Alameda County." (CCSF, supra, at p. 246.) Relying heavily on the purpose of the amendment (discussed below), the court answered this question in the affirmative. In CCSF the court noted that the "undoubted purpose of the amendment was primarily to safeguard the tax revenues of smaller counties wherein large municipal corporations had purchased, or would acquire, extensive holdings and which would, except for the amendment, be exempt from local taxation." (CCSF, supra, 5 Cal.2d at pp. 245-246.) Without such a limitation, the exemption of public property from taxation could result in "serious financial embarrassment" for the disadvantaged counties. (Id. at p. 246.) The argument made to voters when they adopted the amendment had forecast "impending disaster" to "smaller counties" from the loss of revenue caused by larger counties' acquisition of "lands and water rights" to augment the cities' municipal water supplies.11 (5 Cal.2d at p. 246.) In the situation before it, the water rights at issue had been, prior to their acquisition from riparian owners, "part and parcel of the land itself" and had significantly enhanced its taxable value. (Id. at p. 247.) Once stripped of those rights, "the valuation of the land for purposes of taxation was or might be materially reduced ... ." (Ibid.) Therefore, "taking into consideration the objects and purposes of the constitutional amendment," the right must "be deemed to retain those characteristics they possessed when owned by the plaintiff's predecessor in interest," so as to be subject to taxation. (Ibid.)