basis test, the “legitimate governmental interests” served by the statute need not be the Legislature’s actual interests in adopting it nor need they be based upon articulated facts. See Cmty. Res. for Justice v. City of Manchester, 154 N.H. 748, 757 (2007). Accordingly, the Legislature need not declare its reasons for passing the tax; it is sufficient that there are just reasons for the classification. “[T]he constitutionality of a taxation classification depends upon the physical and functional characteristics of the property itself.” Opinion of the Justices, 142 N.H. 102, 107 (1997). The inherent differences between the subjects of taxation and similar property or sources of income justify differing tax treatment. See Smith v. N.H. Dep’t of Revenue Admin., 141 N.H. 681, 690 (1997) (<HOLDING>); Opinion of the Justices, 117 N.H. at 515
recognizing differing elements and standard of proof between medical malpractice and fraud holding that the inherent differences between banks and other financial institutions constituted just reasons for differing tax treatment holding that property tax was a state tax and was thus disproportionate unreasonable and unfair because of discrepancies in tax rates of up to 400 between school districts holding that reasons of economy constitute just cause for abolishing a position recognizing broad authority to classify institutions separately for tax purposes