delivered the following dissenting opinion, in which Collins, J., concurred.
Like most taxes, the Maryland collateral inheritance tax is the product of two factors, the tax rate and the tax base. When section 118 required the Orphans’ Court to “determine * * * what proportion the [life tenant] shall pay of said tax” and thereafter from time to time “what proportion of the residue of said tax shall be paid by the [remaindermen]” and provided that *629each of the remaindermen “shall pay his proportion of said tax”, “tax” meant tax and not “tax rate”, one of the two factors of which the tax is the product. A taxpayer does not pay a “tax rate”; he pays a “tax”.
The plain words of section 118 cannot be changed by giving them the meaning of the different words of sections 119 and 105 and the different previous judicial construction of section 105. When ambiguity exists, three sections relating to the same subject should, if possible, be construed in harmony with each other. When no ambiguity exists and the three sections are in terms different and irreconcilable, only the legislature can substitute uniform provisions. This was done by the Act of 1935 and the Act of 1936. Code of 1939, Article 81, secs. 124, 125. The Attorney General does not contend that these acts are applicable retrospectively to the estate of a decedent who died in 1929.
It is not in point to invoke the general construction of section 105 in the Fisher case and other cases. From 1880 until 1936 section 118 was flatly contrary to the basic theory of the law — indeed to arithmetic itself — in giving a remainderman a double offset for deferred enjoyment in (1) deferment of payment to the time of enjoyment, and also (2) deduction of the value of the life estate, without payment in advance of enjoyment. Section 119 is no more in point. From 1894 to 1935, section 119, unlike section 118, gave the remainderman the choice of two offsets, either deferment of payment or discount for advance payment by deduction of the value of the life estate, but not both. It is no more proper to construe unlikes alike than to construe likes as unlike. In the circumstances, the only rule of construction is, Ita lex scriptd est.
Administrative construction of a statute cannot change the plain meaning of the statute. Moreover, opinions of the Attorney General no earlier than 1917 do not go far toward establishing uniform administration of a statute in force since 1880.
*630A statute imposing a tax should be construed most strongly in favor of the citizen and against the State. Maryland Unemployment Compensation Board v. Albrecht, 183 Md. 87, 92, 36 A. 2d 666. This is the converse of the rule of construction of tax exemptions.
The decree should be affirmed.
Judge Collins authorizes me to say that he concurs in this opinion.