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States, 469 U.S. 70, 76 (1984).
Because the Secretary promulgated section 31.3121(b)(20)-1,
Employment Tax Regs., under his general authority to “prescribe
all needful rules and regulations”, see sec. 7805(a), the Court
owes “the interpretation less deference than a regulation issued
under a specific grant of authority to define a statutory term or
prescribe a method of executing a statutory provision”, see Rowan
Cos. v. United States, 452 U.S. 247, 253 (1981). We defer to the
Secretary’s regulatory interpretation of the Code so long as it
is reasonable. Cottage Sav. Association v. Commissioner, 499
U.S. 554, 560-561 (1991); Natl. Muffler Dealers Association, Inc.
v. United States, 440 U.S. 472, 476-477 (1979). In determining
whether a particular regulation carries out the congressional
mandate in a proper manner, we look to see whether the regulation
harmonizes with the plain language of the statute, its origin,
and its purpose. Natl. Muffler Dealers Association, Inc. v.
United States, supra at 477. A regulation may have particular
force if it is a substantially contemporaneous construction of
the statute by those presumed to have been aware of congressional
intent. Id. If the regulation dates from a later period, the
manner in which it evolved merits inquiry. Id. Other relevant
considerations are the length of time the regulation has been in
effect, the reliance placed on it, the consistency of the
Commissioner’s interpretation, and the degree of scrutiny
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