The General Assembly declined to apply this rule to reimbursable employers such as the Hospital Authority. Since contributing employers and reimbursable employers constitute two separate classifications, and since the classifications themselves are rational and, indeed, operate to the overall benefit of the Hospital Authority and other reimbursable employers, the General Assembly was entitled to treat contributing and reimbursable employers differently and we find no denial of equal protection. See Ingalls Iron Works Co. v. Chilivis, 237 Ga. 479, 482-483 ( 228 S.E.2d 866) (1976); Great Northern Nekoosa Corp. v. Bd. of Tax Assessors, 244 Ga. 624 (2) ( 261 S.E.2d 346) (1979). It should be noted that the Hospital Authority may become a contributing employer by terminating its election to be a reimbursable employer.

Yet marriage and private corporations are creatures of statutes but no one would call them governmental entities. Tax exemptions may be extended to private corporations, Great Northern NekoosaCorp. v. Board of Tax Assessors, 244 Ga. 624 (2) ( 261 S.E.2d 346) (1979), as may the power of eminent domain. Code Ann. § 36-801.

However, this rule of statutory construction is not applicable in the instant case. Under the relevant statutes, there is no doubt that appellant was granted an exemption from taxation on its inventory. See Great Northern Nekoosa Corp. v. Bd. of Tax Assessors, 244 Ga. 624, 626 (2) ( 261 S.E.2d 346) (1979). The only question is whether appellant has waived or forfeited the exemption it has been granted. Under these circumstances, the applicable rule of statutory construction is that "forfeitures and penalties are not favored and statutes relating to them must be strictly construed, and in a manner as favorable to the person against whom the forfeiture or penalty would be exacted as is consistent with fair principles of interpretation.

But the principles of equal protection require only that this classification not be irrational. Ingalls Iron Works Co. v. Chilivis, 237 Ga. 479, 482-483 ( 228 S.E.2d 866) (1976); Great Northern Nekoosa Corp. v. Board of Tax Assessors, 244 Ga. 624 (1979). We hold that distinguishing between counties which had already voted to impose a 1% retail sales tax and those which had not was reasonable, and in fact in all likelihood was calculated to avoid any hiatus between the 1975 and 1979 Acts and to reduce the unnecessary expenditure of tax revenues by obviating the necessity for new referendums in a number of counties.