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Syllabus
doing to reduce the quarters of coverage an employee would otherwise be entitled to claim toward eligibility. No similar concern underlies the tax provisions. The legislative history demonstrates that the 1939 Amendments adopting the "wages paid" rule for taxation were designed to address Congress' worry that, as tax rates increased from year to year, administrative difficulties and confusion would attend the taxation of wages payable in one year, but not actually paid until another year. Pp. 212-214.
(d) The Court is not persuaded Congress incorporated Nierotko's treatment of backpay into the tax provisions when it amended the Social Security Act shortly after Nierotko was decided. Prior to 1946, the FICA and FUTA wage bases were defined in terms of remuneration paid with respect to employment during a given year. The 1946 law amended § 209(a), which defines the Social Security wage base for purposes of benefits calculation, by adopting the "wages paid" language already present in § 209(g), the provision construed in Nierotko. Congress also used identical "wages paid" language in redefining the FICA and FUTA wage bases for tax purposes. Although the legislative history makes clear that Congress sought to achieve conformity between the tax and benefits provisions, the conformity Congress sought had nothing to do with Nierotko's treatment of backpay. Rather, Congress' purpose in amending the FICA and FUTA wage bases for tax and benefits purposes was to define the yardstick for measuring "wages" as the amount paid during the calendar year without regard to the year in which the employment occurred. Because the concern that animates Nierotko's treatment of backpay in the benefits context has no relevance to the tax side, it makes no sense to attribute to Congress a desire for conformity not only with respect to the general rule for measuring "wages," but also with respect to Nierotko's backpay exception. Pp. 214-216.
(e) There is some force to the Company's contention that the Govern-ment's refusal to allocate back wages to the year they should have been paid creates inequities in taxation and incentives for strategic behavior that Congress did not intend. But this case presents no structural unfairness in taxation comparable to the structural inequity in Nierotko's context. In Nierotko, an inflexible rule allocating backpay to the year it is actually paid would never work to the employee's advantage; it could inure only to the detriment of the employee, counter to the thrust of the benefits eligibility provisions. Here, by contrast, the Govern-ment's rule sometimes disadvantages the taxpayer, as in this case; other times it works to the disadvantage of the fisc. Anomalous results must be considered in light of Congress' evident interest in reducing complexity and minimizing administrative confusion within the FICA and
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