This manifest intent is the Court's ultimate guide to statutory interpretation. Setting forth the list of exemptions is within the province of the general assembly. Had it intended to exempt a transfer to a revocable inter vivos trust with a non-family contingent beneficiary, it would have done so. We will not perform this function in its stead. The statutory language is clear and free from any ambiguity.
Statutes are to be read in pari materia only when they relate to the same persons or things.
The Tax Act and the Inheritance and Estate Tax Act relate to different things, the former governing transfers of real estate and the latter relating to the tax implications of succession through a will or by intestacy. Moreover, nothing in the inheritance and estate tax provisions suggests that the definitions applicable to them should be applied to other tax statutes, such as the Tax Act. Accordingly, Steidle's exceptions are denied. In his exceptions to the Court's original decision in this case, Steidle raises constitutional issues for the first time. The Court concludes that Steidle has waived these issues because he failed to raise them in his original arguments to this Court.