Clause; as such, this litigation raises an issue of first impression. Particularly inasmuch as the General Assembly retains “broad authority and wide discretion in matters of taxation,” Clifton v. Allegheny Cnty., 600 Pa. 662, 685, 969 A.2d 1197, 1211 (2009) (citation omitted), I believe it incumbent upon this Court to consider whether the circumstances of this case, and its connection to the unique area of gaming, could potentially render a floor-but-no-ceiling tax constitutionally justifiable. In doing so, we should bear in mind the established precept that tax legislation is presumed valid and the person challenging it has the burden of proving otherwise. See Leventhal v. City of Phila, 518 Pa. 233, 239, 542 A.2d 1328, 1331 (1988); see also Clifton, 600 Pa. at 686, 969 A.2d at 1211 (<HOLDING>). The majority proceeds by analogy to tax cases
holding that a statute must be construed so that no part of the statute is rendered surplusage or superfluous internal quotation marks and citation omitted recognizing that the declaratory judgment act is only procedural and does not create substantive rights internal quotation marks and citations omitted holding that statutes are to be interpreted in accordance with the legislative intent and in a manner that will not render the statutes application absurd unreasonable or unjust internal quotation marks and citation omitted recognizing that absent illegality we do not weigh the wisdom of any particular employment decision internal quotation marks and citation omitted recognizing that a tax enactment will not be invalidated unless it clearly palpably and plainly violates the constitution internal quotation marks and citation omitted