Does the general rule that an ambiguous taxing statute must be construed strictly in favour of the taxpayer apply only to administrative interpretations of the ambiguous tax statutes?

18 Notwithstanding the view of our dissenting colleague, we do not mean to suggest that the general rule that an ambiguous taxing statute must be construed strictly in favor of the taxpayer applies only to administrative interpretations of ambiguous tax statutes. We agree that in certain circumstances the rule may apply to an uncertain tax provision of the Constitution. (See County of Fresno v. Malmstrom, supra, 94 Cal.App.3d at p. 979, 156 Cal.Rptr. 777.) However, mindful "that such a rule does not take precedence over other fundamental rules of statutory construction" (City of Los Angeles v. Belridge Oil Co., supra, 42 Cal.2d at p. 827, 271 P.2d 5), we believe that in this case it must give way to a canon of construction that is rooted in the basic structure of our form of constitutional government, as we explain presently. For this reason, the trial court's reliance on the general rule favoring the taxpayer was error.