Horace Harmon Lurton

“ This classification by the finance committee is to be made with the advice and assistance of 'the commissioner of revenue, the city tax collector, or any city officer.'
The tax imposed is not merely an exercise of the police power regulating a business, but is a tax assessed as a condition upon which the license issues. ”

“ The objection to the ordinance does not grow out of any contention that there may not exist just and reasonable distinctions justifying a greater tax upon some of these persons or firms engaged in doing what is called a 'private banking' business than upon others engaged in the same general business ”

“ But that court, after saying that it was competent for the council to assign private bankers to different classes, and that the plaintiff in error had been required to pay no greater license tax than all others in the same class, said:
'In order to render the classification illegal, the party assailing it must show that the business discriminated against is precisely the same as that included in the class which is alleged to be favored. ”