This appeal is from the District Court's dismissal of a petition to review the bankruptcy referee's adverse ruling on claims of the District of Columbia.1 The major issue involves an alleged clash between the national Bankruptcy Act and the District of Columbia Revenue Act of 1949.

Section 64, sub. a of the Bankruptcy Act2 gives priority to 'taxes * * *owingowing[96 U.S.App.D.C. 170] * * * to the United States or any State or subdivision thereof,' § 64, sub. a(4), after expenses of administration, § 64, sub. a(1), wage claims, § 64, sub. a(2) and certain creditor expenses, § 64, sub. a(3); and § 57, sub. j3 bars allowance of penalties. Section 132 of the District of Columbia Revenue Act of 1949, on the other hand, gives priority to the District of Columbia for unpaid gross sales taxes before all 'claimants of whatsoever kind or nature' and makes penalties and interest thereon 'a prior and preferred claim.'4 The referee held that the Bankruptcy Act governed the District's claim for gross sales taxes, interest and penalties. Accordingly, he allowed only a § 64, sub. a(4) priority for taxes and interest, and applied § 57, sub. j to disallow penalties. The District vigorously contends that the Bankruptcy Act provisions are superseded by § 132 of the District's Revenue Act because that section was enacted later in time and expressly applies 'Whenever the business or property of any person subject to tax * * * shall be placed in receivership or bankruptcy * * *.'5

This contention has considerable force. Literally, 'bankruptcy' is all-inclusive and appears, at first blush, to extend to proceedings under the national Bankruptcy Act. But we are not bound by what 'may appear on 'superficial examination" to be the plain meaning of a word.6 'Words generally have different shades of meaning, and are to be construed if reasonably possible to effectuate the intent of the lawmakers * * *.'7 Our duty to look beyond the apparent meaning of statutory language is particularly clear where, as here, the effect of a literal reading is an implied repeal pro tento of an earlier enactment. 'A law is not to be construed as impliedly repealing a prior law unless no other reasonable construction can be applied.'8 'The problem is to reconcile the two (acts), if possible, and to give effect to each.'9

We think such reconciliation is achieved here under a reasonable construction of the word 'bankruptcy,' as used in § 132 of the District of Columbia Revenue Act, to embrace only proceedings under local insolvency acts. That section follows, almost verbatim, the [96 U.S.App.D.C. 171] Maryland sales tax statute.10 As there used, 'bankruptcy' refers only to state proceedings since the state act obviously could not affect priorities under the national act.11 While Congress in adapting the Maryland law to the District could have used the word 'bankruptcy' in a different sense than in the Maryland act, there is absolutely no evidence in the legislative history that it did. On the contrary, an important objective of the drafting committee was 'to reduce the differences and possible friction * * * between the adjoining areas of Maryland and * * * the District of Columbia * * * by keeping the proposed measure as nearly as possible identical with the Maryland sales tax now in existence.'12 We infer that Congress adhered to the Maryland usage of 'bankruptcy.' This narrows § 132 but by no means eliminates it.13

In addition to the foregoing legislative history, we think other considerations make plain that Congress did not intend to repeal or modify crucially important provisions of so basic a statute as the Bankruptcy Act.14

(1) The Bankruptcy Act of 1867 gave to federal and state taxes a position prior even to costs of administration;15 and this special treatment of taxes was ostensibly continued by the Act of 1898.16 An ambiguity in that act, however, gave rise to '27 years of controversy'17 which was not finally settled until 1926 when Congress expressly fixed the policy which substantially governs the priorities of federal and state taxes under the present act.18 It is unrealistic to assume that Congress intended to create an exception sharply altering this long and well-considered policy without express reference to the Bankruptcy Act.

(2) 'The broad purpose of the Bankruptcy Act is to bring about an equitable distribution of the bankrupt's [96 U.S.App.D.C. 172] estate among creditors holding just demands * * *';19 and, in the execution of that purpose, Congress has established a 'reasonable classification of claims as entitled to priority because of superior equities * * *.'20 Congress expressed no reason-- and we are aware of none-- why the District's claim for its unpaid sales taxes has any greater equity than claims of other governmental units for such taxes. And there is no support in logic or in the legislative history for assuming that Congress changed its mind about the superior equities of claims under §§ 64, sub. a (1), (2) and (3). Moreover, to allow penalties as a 'prior and preferred claim' is sharply at odds with equitable principles traditionally governing the distribution of a bankrupt's estate.

For the foregoing reasons we uphold the rulings below: (1) that the District's claims for sales taxes and interest were entitled to priority only under § 64, sub. a(4) and 'to no other priority whatsoever * * *'; and (2) that interest and penalties on the unpaid sales taxes in excess of six per cent per annum should be disallowed under § 57, sub. j as a penalty.21

The only remaining question on this appeal involves the District's claim for a one per cent per month payment on delinquent personal property taxes. The statute,22 which imposes such taxes and delinquency payments, does not contain a provision like § 132 of the sales tax statute. The District contends that its claim is for interest. But it is in excess of the legal interest rate and the statute specifically designates it a penalty. We therefore agree with the ruling below that the claim is for a penalty which is barred by 57, sub. j of the Bankruptcy Act.

Affirmed.