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OCR: the tax is justified by differences in the nature of the businesses bearing ot not bearing the tax 490 The structure ot section 11503 whole the congressionai purposes underlying The statute and general Commerce Clause principles are congruent 1m suggesting the appropriate analysis The cssential inquiry should be whether t1 tax facially neutral and generally applicable whether it falls 1 railroads alone or as one of relatively smatl and insular group Congress recognized that railroads were easy prey for discriminatory taxation because do not vote and are not casily moved 0 friendlier climes Western ATT Lines, Inc Board of Equatizotion supra 480 U.s (examining history of 4R Act and the overall objective section 11503) When railroads are taxed constituent part f large and diverse group of Joc ...