[465]*465Utter, J.
This case raises the question of whether the recent revision of our inheritance tax laws applies to every estate for which taxes did not become due until after the new law's effective date or to only those estates of decedents who died after that date. We hold that inheritance tax accrues as of the date of death and that the express saving clause in the new law preserved all such obligations existing at the time the law became effective.
Decedent died on April 17, 1981, which under then existing law caused inheritance tax to accrue immediately. See former RCW 83.44.010. Payment of the tax, however, could be, and was in this case, delayed for 9 months, i.e., until January 17, 1982, without penalty. See former RCW 83.44-.010.
In November 1981, the voters passed Initiative 402, now codified as RCW 83.100, to become effective on January 1, 1982. The Initiative substituted an estate tax for the inheritance tax and significantly reduced tax rates. In the present case, for example, the tax due under the old law would have been $14,459.22, while the tax due under the new law would be only $4,596.31. Applying the new law to the estates of all decedents dying in the last 9 months of 1981 would reduce state revenues by $36 million.
That the new law should apply to all estates which had not yet paid taxes as of January 1, 1982, is precisely the argument made by the estate in the present case. The estate refused to pay the amount due under the former law and paid only the amount due under the new law. The Department of Revenue then refused to issue a release. After appropriate statutory procedures (see RCW 83.28) and a hearing, the trial court held in favor of the estate. The State now appeals, arguing (1) that the express saving clause in the initiative preserved the State's right to inheritance taxes already accrued; and (2) that the State's rights had vested as of the date of death and any release of such rights constituted a gift of public funds in violation of Const, art. 8, § 5.
In repealing the former inheritance tax laws and substi[466]*466tuting the current estate tax, Initiative 402 also provided:
These repeals shall not be construed as affecting any existing right acquired under the statutes repealed or under any rule, regulation, or order adopted pursuant thereto; nor as affecting any proceeding instituted thereunder.
Initiative 402, § 83.100.160(2), codified as RCW 83.100-.900(2). Under the former statute, as noted above, inheritance taxes accrued as of the date of death, though payment could be delayed. See former RCW 83.44.010; cf. In re Estate of Fotheringham, 183 Wash. 579, 585-86, 49 P.2d 480 (1935) (treating application of new inheritance tax to pending estate as retroactive). The key issue is whether the State's accrued right to collect inheritance taxes from the estate was an "existing right" protected by this provision.
Initially, the estate argues that any doubt in the meaning of a taxing statute must be resolved in favor of the taxpayer. See Vita Food Prods., Inc. v. State, 91 Wn.2d 132, 134, 587 P.2d 535 (1978). This rule has been generally overemphasized and exaggerated in scope, however.
"The better rule ... is that statutes imposing taxes and providing means for the collection of the same should be construed strictly in so far as they may operate to deprive the citizen of his property by summary proceedings or to impose penalties or forfeitures upon him; but otherwise tax laws ought to be given a reasonable construction, without bias or prejudice against either the taxpayer or the state, in order to carry out the intention of the legislature and further the important public interests which such statutes subserve."
3 C. Sands, Statutory Construction § 66.02 (4th ed. 1974) (quoting State ex rel. Hennepin Cy. v. Brandt, 225 Minn. 345, 351, 31 N.W.2d 5 (1948)) and cases cited therein. See, e.g., Parr v. Department of Rev., 276 Or. 113, 116-17, 553 P.2d 1051 (1976). Accord, Spaulding v. Adams Cy., 79 Wash. 193, 197-98, 140 P. 367 (1914); see also In re Estate of Sweek, 191 Wash. 660, 664, 71 P.2d 657, 113 A.L.R. 386 (1937).
[467]*467We are not inclined to bias our analysis as strongly against the State as suggested by the estate's assertion that "any reasonable interpretations favorable to the widow/ personal representative must be adopted regardless of any other possible interpretations." (Italics ours.) Brief of Respondent, at 11. In any event, the principle of construction advocated by the estate, to the extent that it is appropriate at all, is applicable only when the provision in question, read in the context of the entire statute, is ambiguous. Dravo Corp. v. Tacoma, 80 Wn.2d 590, 595-96, 496 P.2d 504 (1972). We find no significant ambiguity here.
In interpreting Initiative 402, we must look to the voters' intent and the language of the Initiative as the average informed lay voter would read it. See Department of Rev. v. Hoppe, 82 Wn.2d 549, 555, 512 P.2d 1094 (1973). Contrary to the estate's suggestion, we do not find the official ballot title clearly indicative of an intent to abolish all inheritance taxes not yet collected as of the Initiative's date. The title and other analysis in the voters pamphlet express to us only an intent to, as of January 1, 1982, substitute a restricted state death tax for inheritance and gift taxes and preserve "any existing right under the statutes repealed". Official Voters Pamphlet 17 (1981); RCW 83.100.900. The Initiative does not directly address the largely technical question of whether application of the Initiative's provisions should turn on the date of death or the date of payment. The estate's contention that absolute immediacy was a concern is undercut somewhat, however, by the fact that the law was made effective not immediately but 2 months after the election.
The controlling question is how the average informed voter would interpret the words "existing right". See Hoppe, at 555. The estate argues that "right" differs from "obligation" and that while "rights" are preserved, tax "obligations" are not.
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[465]*465Utter, J.
This case raises the question of whether the recent revision of our inheritance tax laws applies to every estate for which taxes did not become due until after the new law's effective date or to only those estates of decedents who died after that date. We hold that inheritance tax accrues as of the date of death and that the express saving clause in the new law preserved all such obligations existing at the time the law became effective.
Decedent died on April 17, 1981, which under then existing law caused inheritance tax to accrue immediately. See former RCW 83.44.010. Payment of the tax, however, could be, and was in this case, delayed for 9 months, i.e., until January 17, 1982, without penalty. See former RCW 83.44-.010.
In November 1981, the voters passed Initiative 402, now codified as RCW 83.100, to become effective on January 1, 1982. The Initiative substituted an estate tax for the inheritance tax and significantly reduced tax rates. In the present case, for example, the tax due under the old law would have been $14,459.22, while the tax due under the new law would be only $4,596.31. Applying the new law to the estates of all decedents dying in the last 9 months of 1981 would reduce state revenues by $36 million.
That the new law should apply to all estates which had not yet paid taxes as of January 1, 1982, is precisely the argument made by the estate in the present case. The estate refused to pay the amount due under the former law and paid only the amount due under the new law. The Department of Revenue then refused to issue a release. After appropriate statutory procedures (see RCW 83.28) and a hearing, the trial court held in favor of the estate. The State now appeals, arguing (1) that the express saving clause in the initiative preserved the State's right to inheritance taxes already accrued; and (2) that the State's rights had vested as of the date of death and any release of such rights constituted a gift of public funds in violation of Const, art. 8, § 5.
In repealing the former inheritance tax laws and substi[466]*466tuting the current estate tax, Initiative 402 also provided:
These repeals shall not be construed as affecting any existing right acquired under the statutes repealed or under any rule, regulation, or order adopted pursuant thereto; nor as affecting any proceeding instituted thereunder.
Initiative 402, § 83.100.160(2), codified as RCW 83.100-.900(2). Under the former statute, as noted above, inheritance taxes accrued as of the date of death, though payment could be delayed. See former RCW 83.44.010; cf. In re Estate of Fotheringham, 183 Wash. 579, 585-86, 49 P.2d 480 (1935) (treating application of new inheritance tax to pending estate as retroactive). The key issue is whether the State's accrued right to collect inheritance taxes from the estate was an "existing right" protected by this provision.
Initially, the estate argues that any doubt in the meaning of a taxing statute must be resolved in favor of the taxpayer. See Vita Food Prods., Inc. v. State, 91 Wn.2d 132, 134, 587 P.2d 535 (1978). This rule has been generally overemphasized and exaggerated in scope, however.
"The better rule ... is that statutes imposing taxes and providing means for the collection of the same should be construed strictly in so far as they may operate to deprive the citizen of his property by summary proceedings or to impose penalties or forfeitures upon him; but otherwise tax laws ought to be given a reasonable construction, without bias or prejudice against either the taxpayer or the state, in order to carry out the intention of the legislature and further the important public interests which such statutes subserve."
3 C. Sands, Statutory Construction § 66.02 (4th ed. 1974) (quoting State ex rel. Hennepin Cy. v. Brandt, 225 Minn. 345, 351, 31 N.W.2d 5 (1948)) and cases cited therein. See, e.g., Parr v. Department of Rev., 276 Or. 113, 116-17, 553 P.2d 1051 (1976). Accord, Spaulding v. Adams Cy., 79 Wash. 193, 197-98, 140 P. 367 (1914); see also In re Estate of Sweek, 191 Wash. 660, 664, 71 P.2d 657, 113 A.L.R. 386 (1937).
[467]*467We are not inclined to bias our analysis as strongly against the State as suggested by the estate's assertion that "any reasonable interpretations favorable to the widow/ personal representative must be adopted regardless of any other possible interpretations." (Italics ours.) Brief of Respondent, at 11. In any event, the principle of construction advocated by the estate, to the extent that it is appropriate at all, is applicable only when the provision in question, read in the context of the entire statute, is ambiguous. Dravo Corp. v. Tacoma, 80 Wn.2d 590, 595-96, 496 P.2d 504 (1972). We find no significant ambiguity here.
In interpreting Initiative 402, we must look to the voters' intent and the language of the Initiative as the average informed lay voter would read it. See Department of Rev. v. Hoppe, 82 Wn.2d 549, 555, 512 P.2d 1094 (1973). Contrary to the estate's suggestion, we do not find the official ballot title clearly indicative of an intent to abolish all inheritance taxes not yet collected as of the Initiative's date. The title and other analysis in the voters pamphlet express to us only an intent to, as of January 1, 1982, substitute a restricted state death tax for inheritance and gift taxes and preserve "any existing right under the statutes repealed". Official Voters Pamphlet 17 (1981); RCW 83.100.900. The Initiative does not directly address the largely technical question of whether application of the Initiative's provisions should turn on the date of death or the date of payment. The estate's contention that absolute immediacy was a concern is undercut somewhat, however, by the fact that the law was made effective not immediately but 2 months after the election.
The controlling question is how the average informed voter would interpret the words "existing right". See Hoppe, at 555. The estate argues that "right" differs from "obligation" and that while "rights" are preserved, tax "obligations" are not.
We are unable to attribute to the voters the technical legal distinction between "right" and "obligation" suggested by the estate. Indeed, the only legal authority mustered in [468]*468support of such a distinction is the fact that two acts passed by the Legislature, in 1961 and 1967, choose to mention both concepts in saving clauses. See Laws of 1967, 1st Ex. Sess., ch. 149, § 63 (enacting RCW 82.98.035); Laws of 1961, ch. 15, §§ 82.98.040, 83.98.040, 84.98.040 (enacting RCW 82.98.040, RCW 83.98.040, and RCW 84.98.040). But see Spokane Cy. v. Northern Pac. R.R., 5 Wash. 89, 90-91, 31 P. 420 (1892) (involving saving clause in former revenue law which spoke only of "existing right[s]" and "proceeding[s] pending"; case decided on other grounds). The estate cites no case making the distinction it suggests and cases in other jurisdictions have expressly included the State's right to collect taxes within the term "existing right". See, e.g., In re Hubbs, 31 Ariz. 252, 263, 265, 252 P. 515 (1926); State ex rel. Caster v. Atchison, T. & S.F. Ry., 99 Kan. 831, 832, 834, 163 P. 157 (1917) (saving statute protecting both "any right accrued" and "any duty imposed"; analyzing State's right to collect inheritance tax as a "right accrued").
Whatever the interpretation of legislators and courts versed in the law, the average informed voter must have construed the word "right" as including the State's right to collect taxes. This was the only significant right provided by the former inheritance and gift tax laws. See generally RCW Title 83. If the voters did not intend to preserve it, what right did they intend to preserve? Exemption rights become superfluous if tax rights are not preserved. While the former statute did also provide certain taxpayer protections such as the refund of overpayments of tax (see, e.g., former RCW 83.44.080), those obligations are secondary to the broader right to tax and were doubtless not the major consideration in the average informed voter's mind.
In addition, the estate's technical distinction between "right" and "obligation", which as we note above has not been consistently made even by legislatures and courts, is a distinction which we seriously doubt the average informed lay voter would make. In common usage, the existence of an obligation toward another implies the existence of a right in the obligee and hence preservation of rights necessarily [469]*469implies preservation of obligations. See Webster's Third New International Dictionary 1556 (1971) (defining "obligation" as "a legal relationship or tie in accordance with which one party is able to compel another . . . to do or not to do a specified act"); Webster's, at 1955 (defining "right" as "a power or privilege vested in a person by the law to demand action or forbearance at the hands of another"). The taxpayer's "obligation" to pay tax is the State's "right" to collect it. No doubt the estate would have no trouble construing the provision for refunds of excess tax payments under the former statute (see, e.g., former RCW 83.44.080) as a "right" of the taxpayer, though it is equally an "obligation" of the State.
We cannot reach any conclusion other than that the average informed voter would have interpreted "right" as including the State's right to tax. It is the intent and interpretation of the average informed voter which should control our decision, not the technical and debatable legal distinction advanced by the estate.
Because of this conclusion we need not consider the State's constitutional argument. The decision of the trial court is reversed.
Williams, C.J., and Dolliver, Dore, and Dimmick, JJ., concur.