How have courts interpreted the words 'all or a substantial portion' or 'reorganization' in the California Tax Code?

One of the many rules laid down in aid of statutory interpretation is that legislative intent should be gathered from the whole Act and reconciled with reasonable application to carry out the policy and purpose of the legislation. (Select Base Materials v. Board of Equalization, 51 Cal.2d 640, 335 P.2d 672; County of Alameda v. Kuchel, 32 Cal.2d 193, 195 P.2d 17; Warner v. Kenny, 27 Cal.2d 627, 165 P.2d 889.)

It is also true that '* * * where the occasion demands it, 'the same words may have different constructions to effectuate the intention' of the act.' (Wall v. Board of Directors, 145 Cal. 468, 473, 78 P. 951, 953.) Therefore, any meaning attributed to 'all or a substantial portion' or 'reorganization' for other purposes, in other parts of the Act, does not control here.