*446Dissenting Opinion by
Mb. Justice Bell :In Pichler v. Snavely, 366 Pa. 568, 79 A. 2d 227, the Court in a unanimous opinion said (page 569) : “The law is well settled that a liquor license is not a property right, but only a purely personal privilege for a specific limited time, which is subject to termination by the Liquor Control Board for cause and which, in any event, terminates with the licensee’s life. A liquor license or the privilege to sell liquors for a specified time, although often very valuable, is not assignable (as that term is generally understood), nor does it* go to the personal representatives or become an asset of the holder’s estate in case of death: Grimm’s Estate, 181 Pa. 233, 236, 37 A. 403; Blumenthal’s Petition, 125 Pa. 412, 415, 18 A. 395; Buck’s Est., 185 Pa. 57, 60, 39 A. 821; Mueller’s Est., 190 Pa. 601, 603, 42 A. 1021; Commonwealth v. Cochran Post No. 251, 350 Pa. 111, 119, 38 A. 2d 250; Spankard’s Liquor License Case, 138 Pa. Superior Ct. 251, 259, 10 A. 2d 899.”
In Ryan Estate, 375 Pa. 42, 99 A. 2d 562 (1953), the Court said (pages 44, 46) : “I. The decedent was the owner of a liquor license. At his death in 1950 the liquor license was transferred to his surviving spouse under the provisions of §408(c) of the Pennsylvania Liquor Control Act of 1937, P. L. 1762, as amended, which provides, inter alia: . . In the case of the death of a licensee, the board may transfer the license to the surviving spouse or personal representative or to a person designated by him.’ . . . [The Court then quoted with approval the law as it had been reiterated in Pichler v. Snavely, 366 Pa., supra.] . . .
“II. The Commonwealth of Pennsylvania appraised at $5,000 the liquor license which the surviving spouse had obtained from the Liquor Control Board. The claim for inheritance tax was allowed by the court be*447low. For the reasons heretofore stated, said license so issued under the Pennsylvania Liquor Control Act to the surviving spouse was her individual property. In addition, it was not{property of which the decedent was seised or possessed at the time of his death’ (under the Act of 1919, 72 PS §2301, as amended) : McCandless Estate, 374 Pa. 551, 97 A. 2d 807. Since the decedent’s license terminated at his death, and was not property of which he was seised or possessed at the time of his death, it is somewhat difficult to understand at what point of time it could have become an asset of the estate.”
In Blumenthal’s Petition, 125 Pa., supra (1889), this Court dismissed an appeal from the refusal of a petition to transfer a liquor license. In that case the Court held that under the Act of 1858 the Courts of Quarter Sessions have power to transfer a license to sell liquors, but the power is discretionary, as, admittedly, it is under the present law. The Court, speaking through Mr. Chief Justice Paxson, said (page 415) : “While it is true, as was said in Eaudenbusch’s Petition, 120 Pa. 328, that ‘neither the petitioner nor any other person in this state has any property in the right to sell liquors,’ yet it is also true that when the state grants a license to a man for that purpose, the latter acquires a privilege to sell liquors for a specified time, for which he has paid the Commonwealth a valuable consideration. The privilege, however, is personal, and is not assignable, nor does it go to the personal representatives in case of death.”
Ryan Estate and all the prior decisions held that the value of a liquor license and the value of the right to apply for a transfer thereof were not subject to the Pennsylvania inheritance tax. That has been the law of Pennsylvania from 1889 until today, iterated and reiterated many times by this Court. It is now expressly overruled and we believe 7 other decisions of this *448Court covering a period of 70 years are impliedly overruled. We are tempted in this case, as in nearly 50 additional cases decided in the last few years, to pose the question “stare decisis quo vadis?”
Even if the law which has existed for over 70 years is overruled, the majority is still confronted with and confounded by the language of the taxing Act and the applicable principles of interpretation.
A liquor license is issued for a period of one year. The majority opinion admits that at least between the Commonwealth and the licensee “the license is simply a personal privilege subject to termination for cause or upon the death of the licensee; by its very nature the license itself does not become an asset of the estate of the deceased licensee.” However, the majority decide that by virtue of legislative fiat “the right to apply for such transfer is a right which possesses value” and therefore it must be subject to inheritance tax. Of course, this is a non sequitur and flies in the teeth of the language of the Pennsylvania Inheritance Tax Act and the principles governing the interpretation thereof. The Pennsylvania Inheritance Tax Act of June 20, 1919, P. L. 521, as amended, provides: “Article I. Imposition and Bate of Tax. Section 1. . . . That a tax shall be and is hereby, imposed upon the transfer of any property, real or personal, ... to persons or corporations in the following cases: (a) When the transfer is by will or by the intestate laws of this Commonwealth' from any person dying seized or possessed of the property while a resident of the Commonwealth, whether the property be situated within this Commonwealth or elsewhere.”
The Act could not be clearer. It taxes only the transfer or passing of property, i.e., the interest of the testator or intestate (Section 45) from any person dying seized or possessed of the property. Even if, contrary to all the foregoing decisions, a liquor license is *449considered property and not a personal privilege, everyone agrees that it terminates at the death of the licensee-decedent, and it is not and ivas not assignable.* Certainly within the meaning of the Inheritance Tax Act the decedent did not die seized or possessed of property or of any interest therein, which because it was his was transferable by him by will or under the intestate laws. It is, we repeat, not property of the decedent which he can transfer in any way, shape or form and hence under the clear language of the Act and likewise under the pertinent authorities is not subject to the Pennsylvania Inheritance Tax. “Acts imposing a tax must be strictly construed against the Commonwealth and all reasonable doubt must be resolved in favor of the taxpayer: Commonwealth v. Budd Company, 379 Pa. 159, 108 A. 2d 563; Allentown School District Mercantile Tax Case, 370 Pa. 161, 87 A. 2d 480; Murray v. Philadelphia, 364 Pa. 157, 71 A. 2d 280; Commonwealth v. Repplier Coal Co., 348 Pa. 372, 35 A. 2d 319.” Loeb Estate, 400 Pa. 368, 372, 162 A. 2d 207. Accord: Tax Review Board v. Belmont Laboratories Company, 392 Pa. 473, 141 A. 2d 234; Paper Products Co. v. Pittsburgh, 391 Pa. 87, 137 A. 2d 253. In other words, if there is any reasonable doubt as to the validity of a tax Act or what it covers, or whether it includes and governs the matter involved in a particular case, the taxing statute must be construed in favor of the taxpayer and most strongly against the Government. So construed the license is clearly not subject to tax and the uncertain right which the liquor law gives a surviving spouse cannot possibly make a right in favor of a widow, “property of the decedent.”
Moreover and equally important it is impossible to determine at decedent’s death- — and that is the time at *450which the value of the opportunity of asking the liquor board to transfer the license must be ascertained and determined — the value of the decedent’s license which under the law terminates at his death and which admittedly is not a part of his estate. We repeat, there is no absolute or vested right in the deceased licensee, nor indeed in his widow or his personal representative, to have the liquor license transferred to the widow or to anyone. The language of the liquor control statute is clear. The Liquor Control Board has a right in its sole discretion to transfer or not transfer the license, and to do it if, as and when it desires and then only for the balance of the yearly term for which it was issued. The instant case aptly illustrates the impossibility of ascertaining and determining (or doing anything except make a wild guess of) the value at time of decedent’s death of this so-called opportunity to have the Liquor Control Board in its sole discretion at some future undeterminate time transfer the license. That point and the impossibility of doing anything but guess as to the value of the “opportunity” at the death of the licensee has been overlooked or glossed over by the majority. Decedent died on January 16, 1859. It was not until March 4, 1959 that the Liquor Control Board authorized a transfer of the decedent’s liquor license to Goldman, an individual. It is, we repeat, clear as crystal that no one could fairly, reasonably or accurately determine as of January 16, 1959 what was the value to decedent’s estate of the liquor license which terminated at decedent’s death and which it could not sell, or the value of the oppoi*tunity which the law gave to a widow or personal representative to have a transfer made or refused at the sole discretion of the Board at an indeterminable future time.
Lord Coke’s famous maxim which has guided Bench and bar and text authorities for over 300 years has apparently been embalmed in the Dead Sea, or lost in the *451desert sands of Sahara. As Mr. Justice Owen J. Egberts aptly said in Smith v. Allwright, 321 U. S. 649, 669: . . the instant decision, overruling that announced about nine years ago, tends to bring adjudications of this tribunal into the same class as a restricted railroad ticket, good for this day and this train only.” In the last few years this Court has overruled more than a score of rules or principles long established and recently reiterated by the Supreme Court of Pennsylvania. Some of the decisions which were overruled had been handed down within the last three years and some within a period of months. To say that I am deeply concerned with this trend which has created such instability and uncertainty in nearly every field of the law is a gross understatement. To paraphrase Justice Egberts' words, this decision like many others made by the present Court tends to bring every decision of this Court into the same class as a restricted railroad ticket marked good for this day and this train only and then only until a new passenger gets aboard at the next station stop.
Italics throughout, ours.
Section 468, Act of April 12, 1951, P, L. 90, as amended January 26, 1956, P. L. 966.