Mobley, Justice.
1. This case is here on grant of certiorari to the Court of Appeals in Carter v. Oxford, 102 Ga. App. 762 (118 S. E. 2d 216). The case involves a tax question which is of importance in the administration of the Georgia income tax law.
After careful consideration of the records and briefs of counsel, we are of the opinion that the Court of Appeals was correct in holding that the distribution of all the assets of the corporation to its stockholder in complete and final liquidation of all of his stock should be treated, as provided in Code Ann. § 92-3120 (d), as a sale of his stock and the entire gain computed and taxed accordingly, that is, as a capital gain under Code Ann. § 92-3119 (d) (Ga. L. 1952, p. 405 et seq.) The facts, issues, and reasons for their conclusions are well stated by the Court of Appeals in the opinion by Presiding Judge Townsend and concurring opinion by Judge Frankum, and we will not restate them here. However, the question of whether Code Ann. § 92-3002 (o) (Ga. L. 1937, pp. 109, 112) is open to judicial construction is so vital to a decision in this case that we will elaborate upon the discussion of it by the Court of Appeals.
[822]*822The Commissioner insists that the only question presented is a legal question, that is, whether Code Ann. § 92-3002 (o), which defines dividends and also states, “It [the word ‘dividend’] includes such portion of the assets of a corporation distributed at the time of dissolution as would in effect be a distribution of earnings” means what it says or not. The Commissioner’s position is that the language of this section is clear and unambiguous and that, as stated in Aldridge v. Federal Land Bank of Columbia, 203 Ga. 285 (46 S. E. 2d 578), “If the legislature does plainly and distinctly declare its intention, the act is not open to construction; it needs, and can receive none.”
We have no argument with the quoted statement of law, and we agree that, unless § 92-3002 (o) is open to construction, the Commissioner is correct in his contention that the taxpayer is not entitled to capital-gains treatment on gains received upon the liquidation of his corporation.
The rule which states that a statute which is clear and unambiguous may not be judicially construed has no application in this case for any one of three reasons:
(1) The instant case is not one involving one statute; three statutes must be read and considered together. The three statutes which must be considered are: (a) '§ 92-3120 (d), enacted in 1931, which treats corporate distributions on liquidation as sales. (b) § 92-3002 (o), enacted in 1937, which defines dividends and also states, “It [the word ‘dividend’] includes such portion of the assets of a corporation distributed at the time of dissolution as would in effect be a distribution of earnings.” (c) § 92-3119 (d), which is the capital-gains section of the Code.
The ultimate question for decision is whether the gain realized will be treated as capital gain or ordinary income, and that question cannot be answered by a consideration of Code Ann. § 92-3002 (o) alone.
In the construction of a statute, all laws in pari materia should be considered in order to ascertain the intention of the legislature. Harrison v. Walker, 1 Ga. 32. A statutory rule must be construed consistently with the whole system of pleading and practice of which it forms a part. McDougald v. Dougherty, 14 Ga. 674.
[823]*823To the above rules on pari materia, Georgia has recognized, by way of obiter dictum, an exception. In Ryan v. Commissioners of Chatham County, 203 Ga. 730 (48 S. E. 2d 86), it was stated that statutes in pari materia could not be looked to where the language of the statute under consideration was clear and unambiguous. In this case, however, that rule comes into conflict with other recognized and well-settled rules of statutory construction, viz.: (1) Repeals by implication are not favored. Murray v. State, 112 Ga. 7 (37 S. E. 111); Cornwell v. Atlanta Trust Co., 177 Ga. 303 (170 S. E. 194); Moore v. State, 150 Ga. 679 (104 S. E. 907). (2) The intention of the legislature is the cardinal guide to construction of statutes and, when plainly collected, should be carried into effect, though contrary to the literal sense of terms. Erwin v. Moore, 15 Ga. 361. (3) Where a statute is susceptible of two constructions, one of which would render it meaningless, the intention of the legislature should be construed so as not to render the statute absurd and ineffective. Stelling v. Richmond County, 81 Ga. App. 571 (59 S. E. 2d 414); Scott v. Mayor &c. of Mount Airy, 186 Ga. 652 (198 S. E. 693).
Thus, when a literal interpretation of a statute would have the effect of (1) repealing a prior statute by implication, and (2) rendering the statute under consideration meaningless, the court should consider all statutes in pari materia and attempt to reconcile and harmonize them whenever possible.
(2) The 1937 statute is ambiguous, and for that reason it is capable of judicial construction.
Even if the statute is read alone, it is ambiguous. It does not plainly mean what the Commissioner says it means. First, in the corporate field the terms “dividend” and “distribution of earnings” signify recurrent distributions from a continuing corporate enterprise, and not the final distribution in liquidation. Second, the subjunctive language, “as would in effect be,” is deliberately qualified and clearly indicates that the provision is intended to deal with unusual dissolution situations. The statute is not a clear and simple statute imposing a mathematical test, but rather is a statute imposing in qualified language a test which is based on the “effect” of corporate transactions, and [824]*824necessarily requires a comparison of the transactions involved with ordinary dividend transactions.
An ambiguity arises because the phrase “distribution of earnings” is capable of two reasonable interpretations. It might mean a recurrent distribution of a continuing corporation, i.e., a dividend, as contended by the taxpayer or, given a literal interpretation, it might mean any transfer of earnings to a shareholder at any time whatever.
Furthermore, in determining whether or not the statute is ambiguous, the court need not consider it by itself without reference to other statutes on the same subject. As stated in Carroll v. Ragsdale, 192 Ga. 118 (15 S. E. 2d 210), “Seeking secret legislative meanings at variance with the language used is a perilous undertaking which is quite as apt to lead to an amendment of the law by judicial construction as it is to arrive at the actual thought in the legislative mind. . . But where an ambiguity exists either because of uncertainty in the meaning of words, conflicts with previous laws, or conflicts between different clauses in the same statute, courts should look beyond the verbiage and discover the intent.” (Italics ours.)
When Code Ann. § 92-3002 (o) is read with Code Ann. § 92-3120 (d), a previous law on the same subject in the same title of the Code, the ambiguity becomes apparent.
(3) Even if the statute is not ambiguous, it may be construed because to give it a literal interpretation would render it meaningless.
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Mobley, Justice.
1. This case is here on grant of certiorari to the Court of Appeals in Carter v. Oxford, 102 Ga. App. 762 (118 S. E. 2d 216). The case involves a tax question which is of importance in the administration of the Georgia income tax law.
After careful consideration of the records and briefs of counsel, we are of the opinion that the Court of Appeals was correct in holding that the distribution of all the assets of the corporation to its stockholder in complete and final liquidation of all of his stock should be treated, as provided in Code Ann. § 92-3120 (d), as a sale of his stock and the entire gain computed and taxed accordingly, that is, as a capital gain under Code Ann. § 92-3119 (d) (Ga. L. 1952, p. 405 et seq.) The facts, issues, and reasons for their conclusions are well stated by the Court of Appeals in the opinion by Presiding Judge Townsend and concurring opinion by Judge Frankum, and we will not restate them here. However, the question of whether Code Ann. § 92-3002 (o) (Ga. L. 1937, pp. 109, 112) is open to judicial construction is so vital to a decision in this case that we will elaborate upon the discussion of it by the Court of Appeals.
[822]*822The Commissioner insists that the only question presented is a legal question, that is, whether Code Ann. § 92-3002 (o), which defines dividends and also states, “It [the word ‘dividend’] includes such portion of the assets of a corporation distributed at the time of dissolution as would in effect be a distribution of earnings” means what it says or not. The Commissioner’s position is that the language of this section is clear and unambiguous and that, as stated in Aldridge v. Federal Land Bank of Columbia, 203 Ga. 285 (46 S. E. 2d 578), “If the legislature does plainly and distinctly declare its intention, the act is not open to construction; it needs, and can receive none.”
We have no argument with the quoted statement of law, and we agree that, unless § 92-3002 (o) is open to construction, the Commissioner is correct in his contention that the taxpayer is not entitled to capital-gains treatment on gains received upon the liquidation of his corporation.
The rule which states that a statute which is clear and unambiguous may not be judicially construed has no application in this case for any one of three reasons:
(1) The instant case is not one involving one statute; three statutes must be read and considered together. The three statutes which must be considered are: (a) '§ 92-3120 (d), enacted in 1931, which treats corporate distributions on liquidation as sales. (b) § 92-3002 (o), enacted in 1937, which defines dividends and also states, “It [the word ‘dividend’] includes such portion of the assets of a corporation distributed at the time of dissolution as would in effect be a distribution of earnings.” (c) § 92-3119 (d), which is the capital-gains section of the Code.
The ultimate question for decision is whether the gain realized will be treated as capital gain or ordinary income, and that question cannot be answered by a consideration of Code Ann. § 92-3002 (o) alone.
In the construction of a statute, all laws in pari materia should be considered in order to ascertain the intention of the legislature. Harrison v. Walker, 1 Ga. 32. A statutory rule must be construed consistently with the whole system of pleading and practice of which it forms a part. McDougald v. Dougherty, 14 Ga. 674.
[823]*823To the above rules on pari materia, Georgia has recognized, by way of obiter dictum, an exception. In Ryan v. Commissioners of Chatham County, 203 Ga. 730 (48 S. E. 2d 86), it was stated that statutes in pari materia could not be looked to where the language of the statute under consideration was clear and unambiguous. In this case, however, that rule comes into conflict with other recognized and well-settled rules of statutory construction, viz.: (1) Repeals by implication are not favored. Murray v. State, 112 Ga. 7 (37 S. E. 111); Cornwell v. Atlanta Trust Co., 177 Ga. 303 (170 S. E. 194); Moore v. State, 150 Ga. 679 (104 S. E. 907). (2) The intention of the legislature is the cardinal guide to construction of statutes and, when plainly collected, should be carried into effect, though contrary to the literal sense of terms. Erwin v. Moore, 15 Ga. 361. (3) Where a statute is susceptible of two constructions, one of which would render it meaningless, the intention of the legislature should be construed so as not to render the statute absurd and ineffective. Stelling v. Richmond County, 81 Ga. App. 571 (59 S. E. 2d 414); Scott v. Mayor &c. of Mount Airy, 186 Ga. 652 (198 S. E. 693).
Thus, when a literal interpretation of a statute would have the effect of (1) repealing a prior statute by implication, and (2) rendering the statute under consideration meaningless, the court should consider all statutes in pari materia and attempt to reconcile and harmonize them whenever possible.
(2) The 1937 statute is ambiguous, and for that reason it is capable of judicial construction.
Even if the statute is read alone, it is ambiguous. It does not plainly mean what the Commissioner says it means. First, in the corporate field the terms “dividend” and “distribution of earnings” signify recurrent distributions from a continuing corporate enterprise, and not the final distribution in liquidation. Second, the subjunctive language, “as would in effect be,” is deliberately qualified and clearly indicates that the provision is intended to deal with unusual dissolution situations. The statute is not a clear and simple statute imposing a mathematical test, but rather is a statute imposing in qualified language a test which is based on the “effect” of corporate transactions, and [824]*824necessarily requires a comparison of the transactions involved with ordinary dividend transactions.
An ambiguity arises because the phrase “distribution of earnings” is capable of two reasonable interpretations. It might mean a recurrent distribution of a continuing corporation, i.e., a dividend, as contended by the taxpayer or, given a literal interpretation, it might mean any transfer of earnings to a shareholder at any time whatever.
Furthermore, in determining whether or not the statute is ambiguous, the court need not consider it by itself without reference to other statutes on the same subject. As stated in Carroll v. Ragsdale, 192 Ga. 118 (15 S. E. 2d 210), “Seeking secret legislative meanings at variance with the language used is a perilous undertaking which is quite as apt to lead to an amendment of the law by judicial construction as it is to arrive at the actual thought in the legislative mind. . . But where an ambiguity exists either because of uncertainty in the meaning of words, conflicts with previous laws, or conflicts between different clauses in the same statute, courts should look beyond the verbiage and discover the intent.” (Italics ours.)
When Code Ann. § 92-3002 (o) is read with Code Ann. § 92-3120 (d), a previous law on the same subject in the same title of the Code, the ambiguity becomes apparent.
(3) Even if the statute is not ambiguous, it may be construed because to give it a literal interpretation would render it meaningless.
“While we recognize the rule that statutes in pari materia may not be resorted to where the language of the statute under consideration is clear, it is equally as well settled that, where the terms of the statute to- be construed are ambiguous or its significance is of a doubtful character, it becomes necessary to give proper consideration to other related statutes in order to ascertain the legislative intent in reference to the whole system of laws of which the doubtful statute is a part.” (Italics ours.) Ryan v. Commissioners of Chatham County, 203 Ga. 730, 732, supra.
In Board of Tax Assessors of Decatur County v. Catledge, 173 Ga. 656 (160 S. E. 909), this court treated the problem as follows:
“The cardinal rule in the construction of legislative enactments [825]*825is to ascertain the true intention of the General Assembly in the passage of the law. As a general rule, the use of plain and unequivocal language in a legislative enactment obviates any necessity for judicial construction, and indeed forbids an interpretation of the meaning of the words employed by the General Assembly.”
“An exception to the general rule just stated is presented by the use of words the meaning of which in general acceptation is apparently obvious, and yet the purpose of the legislature would be defeated were the words employed construed literally. Courts may construe the language employed in the act in connection with the context, and ascertain the legislative intent as derived from the old law, the evil, and the remedy, and will not defeat the intention and purpose of the General Assembly by giving effect to words which would render the purpose of the General Assembly in the passage of the enactment futile, unenforceable, or ineffectual.”
These principles of law were forcefully reiterated in Gazan v. Heery, 183 Ga. 30 (187 S. E. 371, 106 A.L.R. 498).
Thus, it is apparent that, if a literal interpretation of a clear and unambiguous statute would render the statute meaningless, the court may consider other statutes on the same subject with the statute in question.
If the interpretation urged by the Commissioner is accepted, i. e., the literal interpretation, the statute would have been meaningless when passed.
Why would the General Assembly, in 1937, pass a law to tax distributions on liquidation of corporations at ordinary income rates when such distributions were already taxed at ordinary income rates and the capital gains provisions were not added to the Code until 1952?
The taxpayers’ explanation for the 1937 enactment is more plausible. They contend that in 1937 the common corporate practice was to liquidate corporations at their depression value and take losses on the difference between the value at that date and the sole stockholder’s cost or original basis for the stock. In this manner earnings could be withdrawn from a corporation without paying any tax whatever.
[826]*826It is obvious then that a literal interpretation of Code Ann. § 92-3002 (o) would render it meaningless when enacted. Rather than ascribe such an intent to the General Assembly, the court should construe the statute with other statutes on the same subject.
2. Accordingly, since the statute is open to construction, the Court of Appeals properly looked to the legislative intent in enacting Code Ann. § 92-3002 (o). Without repeating their review of the history of the legislation and their analysis of the questions involved in determining the legislative intent, suffice it to say that we are of the opinion that the Court of Appeals reached the correct conclusion in holding that the General Assembly did not intend by the enactment of Code Ann. § 92-3002 (o) in 1937 to repeal Code Ann. § 92-3120' (d), which was enacted in 1931; that the last sentence of Code Ann. § 92-3002 (o), defining the word “dividend” to include “such portion of the assets, of a corporation distributed at the time of dissolution as would in effect be a distribution of earnings,” does not apply to bona fide liquidations of corporations, as in this case, and that the distribution to this taxpayer of the assets of the corporation should be treated as a sale of the stock of the corporation, and the gain computed as a capital gain and taxed accordingly under Code Ann. § 92-3119 (d).
Judgment affirmed.
All the Justices concur, except Duckworth, C. J., Head, P. J., and Candler, J., who dissent.