[Cit.]'" Oxford v. Macon Telegraph c. Co., 104 Ga. App. 788, 791 ( 123 S.E.2d 277) (1961). The fact that this provision is a rule enacted by an agency pursuant to a grant of legislative authority does not change our duty, as such rules have the force of law.
' " (Citations omitted; emphasis in original.) Oxford v. Macon Telegraph c. Co., 104 Ga. App. 788, 791-92 ( 123 S.E.2d 277) (1961). "The general rule [is] that where two parts of an [a]ct are in contradiction to each other the latter will prevail. . . ."
Neither does it invest a company statement with an aura of irrefutability, making it impenetrable by facts, but the trustee adduced no evidence tending to show what such facts may have been. It is common knowledge that only in most extraordinary circumstances are the book values of assets, especially intangible assets, equal to their true value. Compare the corporate franchise tax case of Oxford v. Macon Telegraph Publishing Co., 1961, 104 Ga. App. 788, 123 S.E.2d 277, which cites Edwards v. Douglas, 1925, 269 U.S. 204, 46 S.Ct. 85, 70 L.Ed. 235. Carroll testified that other parties were seeking to buy the business, and that he had offered the business for sale for a million dollars.
as surplus subject tothe South Carolina license or franchise tax: 19 Am. Jur.2d 288, Sec. 812; 252 U.S. 189, 65 L.Ed. 521, 9 A.L. R. 1570; 313 F.2d 331; 18 Am. Jur.2d Corporations, p. 735, Sec. 208; 184 Ga. 135, 190 S.E. 654, 110 A.L.R. 465; 13 Am. Jur. 302, Corporations, Sec. 177; 313 F.2d 331; 230 S.C. 357, 95 S.E.2d 628; 174 S.C. 359, 177 S.E. 653; 271 U.S. 50, 46 S.Ct. 375, 45 A.L.R. 1495. Messrs. McKay, McKay, Black Walker, of Columbia, and Gene F. Presley, of Atlanta, Georgia, of Counsel, forRespondent, cite: As to exceptions, not complying withSection 3, Rule 8, not needing to be argued: 236 S.C. 355, 114 S.E.2d 502. As to a transfer of dollars from anearned surplus account to a capital account not constitutingdollars paid in as surplus and therefore not subject to thetax: 252 U.S. 189, 65 L.Ed. 521, 9 A.L.R. 1570; Webster's New International Dictionary, (2d. Ed.); 269 U.S. 204, 46 S.Ct. 85, 70 L.Ed. 235; 44 F. Supp. 960; 256 U.S. 377, 65 L.Ed. 998, 41 S.Ct. 528; 313 F.2d 331; 104 Ga. App. 788, 123 S.E.2d 277; 271 U.S. 50, 46 S.Ct. 375, 45 A.L.R. Messrs. Daniel R. McLeod, Attorney General, and Joe L.Allen, Jr. and Joseph C. Coleman, Assistant AttorneysGeneral, of Columbia, for Appellant, in Reply.
We find no unconstitutional vagueness in the standards of the act before us. Cf. Oxford v. Macon Telegraph Publishing Company, 104 Ga. App. 788, 123 S.E.2d 277 ( Ct. App. 1961). VII. DISCRIMINATION