Since the Miller case the compensation act has been amended several times, but the Legislature has never attempted to override the limitations read into it by the Miller opinion. There were comprehensive amendments in the 1937 reenactment, more than a year after this Court's decision in the Tipton case established that the compensation remedy could be made exclusive, but still the Legislature took no action. Under these circumstances we are of the opinion that the interpretation of the Supreme Court of Pennsylvania of its own Workmen's Compensation Act and of the jurisdiction of its courts over claims arising under the Safety Appliance Act is binding upon the federal courts and should be followed. Buhl's Estate, 300 Pa. 29; 150 A. 86.Pa. Laws 1937, Act No. 282, § 52(4).

The statute merely states what has been the common law of Pennsylvania for some time. See In re Buhl's Estate, 300 Pa. 29, 150 A. 86. The truth of the matter is the Supreme Court of Pennsylvania erroneously construed the scope of the Federal Safety Appliance Acts in Miller v. Reading Co. in 1928.

This is a fundamental rule. See Com. v. Philadelphia Rapid Transit Company, 287 Pa. 190, 134 A. 455; General Assembly v. Gratz, 139 Pa. 497, 20 A. 1041 (in which the principle of strict construction was applied to a personal property tax); In re Buhl's Estate, 300 Pa. 29, 150 A. 86. "Second: A construction which would result in double taxation is to be avoided. Fidelity Company v. Loughlin, 139 Pa. 612, 21 A. 163; Com. v. Megargee Bros., 275 Pa. 12, 118 A. 541; In re Arrott's Estate, 322 Pa. 367, 185 A. 697.

Verizon Pa., Inc. v. Commonwealth , 633 Pa. 578, 127 A.3d 745, 757 (2015) ("One of the most venerable and fundamental tenets of statutory interpretation is that, whenever our Court has interpreted the language of a statute, and the General Assembly subsequently amends or reenacts that statute without changing that language, it must be presumed that the General Assembly intends that our Court's interpretation become part of the subsequent legislative enactment."); Parisi v. Philadelphia Zoning Bd. of Adjustment , 393 Pa. 458, 143 A.2d 360, 363 (1958) (same); In re Buhl's Estate , 300 Pa. 29, 150 A. 86, 87 (1930) (same). See also Commonwealth v. Shaffer , 557 Pa. 453, 734 A.2d 840, 844 (1999) ("once this Court interpreted the legislative language contained in the applicable act, our interpretation became part of the legislation from the date of its enactment."); In re Lock's Estate , 431 Pa. 251, 244 A.2d 677, 683 (1968) (citation omitted)

in a statute, the General Assembly in subsequent statutes on the same subject matter intends the same construction to be placed upon such language"); see alsoVerizon Pennsylvania, Inc. v. Commonwealth , 633 Pa. 578, 127 A.3d 745, 757 (2015) ("[o]ne of the most venerable and fundamental tenets of statutory interpretation is that, whenever our Court has interpreted the language of a statute, and the General Assembly subsequently amends or reenacts that statute without changing that language, it must be presumed that the General Assembly intends that our Court's interpretation become part of the subsequent legislative enactment"); Parisi v. Philadelphia Zoning Bd. of Adjustment , 393 Pa. 458, 143 A.2d 360, 363 (1958) ("long established rule ... that when, in a later legislative enactment, the same language is used as in a prior cognate statute, which has been construed by us, the presumption is that the language thus repeated is to be interpreted in the same way it previously had been"); In re Buhl's Estate , 300 Pa. 29, 150 A. 86, 87 (1930) (same).After careful review, we agree with Jet-Set that the 2003 amendments to Section 4-493(14) do not evidence an intent on the part of the General Assembly to alter the meaning of "frequent" from the one established in Speranza , and in fact, the legislature's continued use of the term reflects an intent to approve of Speranza 's definition.

Estate of Lock, 244 A.2d at 682-83. See, e.g., Parisi v. Philadelphia Zoning Board of Adjustment, 393 Pa. 458, 143 A.2d 360, 363 (1958); Salvation Army Case, 349 Pa. 105, 36 A.2d 479, 481 (1944); Buhl's Estate, 300 Pa. 29, 150 A. 86, 87 (1930); Bell v. Bell, 287 Pa. 269, 135 A. 219, 220 (1926). Although DuPuy's Estate, 373 Pa. 423, 96 A.2d 318, 320 (1953), implicitly suggests a presumption based upon Superior Court precedent, it was not until our decision in Estate of Lock that a presumption based upon intermediate appellate court case law was made clear.

The fact that the statutory language employs two prongs of the four-pronged common law test justifies the conclusion that the legislature intended to incorporate the prior case law as it related to those two elements. Cf. Commonwealth v. Sitkin's Junk Co., 412 Pa. 132, 194 A.2d 199 (1963); Parisi v. Philadelphia Zoning Board of Adjustment, 393 Pa. 458, 143 A.2d 360 (1958); In re Buhl's Estate, 300 Pa. 29, 150 A. 86 (1930). We conclude, upon careful examination of the issues in question, that the test has not been met and that the court below was correct in ruling that this evidence did not qualify as after-discovered evidence which would require the disturbing of the judgment of sentence.

In Troutman this Court was interpreting the Act of June 1, 1889, P. L. 420 (repealed) and has since held that similar language in the 1989 act and the Act of June 17, 1913, P. L. 507 are presumptively construed to have the same meaning. Buhl's Estate, 300 Pa. 29, 32, 150 A. 86, 87 (1930). Both statutes imposed taxes on similar classes of property to the extent of every "dollar of value thereof."

The Local Tax Enabling Act applies not only to cities of the second class, but also to cities of the second class A, cities of the third class, boroughs, towns, townships of the first class, townships of the second class, school districts of the second class, school districts of the third class, and school districts of the fourth class. See, e.g., Buhl's Estate, 300 Pa. 29, 150 A. 86 (1930); Mattern v. Canevin, 213 Pa. 588, 63 A. 131 (1906). We note that The Local Tax Enabling Act specifically forbids taxing membership in golf clubs, see 53 P. S. § 6902(7).

That action of itself was presumptively tantamount to legislative approval of our earlier construction of the identical language: Bogdan v. School District of Coal Township, 369 Pa. 147, 152, 85 A.2d 139. Thus, the Board's contention comes face to face at the outset with the familiar and long established rule of statutory construction that when, in a later legislative enactment, the same language is used as in a prior cognate statute, which has been construed by us, the presumption is that the language thus repeated is to be interpreted in the same way it previously had been when we passed upon the earlier enactment: Buhl's Estate, 300 Pa. 29, 32, 150 A. 86. See, also, Bell v. Bell, 287 Pa. 269, 273, 135 A. 219, and Spangler's Estate, 281 Pa. 118, 123 126 A. 252. As recognized in Lower Nazareth Township Supervisors' Appeal, 341 Pa. 171, 175, 19 A.2d 92, the foregoing rule has been codified as subsection (4) of Section 52 of the Statutory Construction Act of May 28, 1937, P. L. 1019, 46 P. S. § 552(4). The Board's contention is confronted by the further barrier that implied repeals are not favored by the law: Scott v. Bell, 344 Pa. 243, 246, 25 A.2d 308, and H. C.Frick Coke Company Appeal, 352 Pa. 269, 274, 42 A.2d 532. Of course, that does not mean that the additional obstacle cited is insurmountable in all instances. There may, indeed, be an implied repeal of a legislative enactment.