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Opinion of the Court
should have been paid but "were not paid as usual," 327 U. S., at 370. Given this construction of § 209(g), now codified in 42 U. S. C. § 413(a)(2), we cannot say that the FICA and FUTA provisions prescribing tax rates based on wages paid during a calendar year, codified in 26 U. S. C. §§ 3111(a), 3301, have a plain meaning that precludes allocation of back-pay to the year it should have been paid. Cf. Hilton v. South Carolina Public Railways Comm'n, 502 U. S. 197, 205 (1991) ("stare decisis is most compelling" where "a pure question of statutory construction" is involved).
B
From here, we part ways with the Company. Although we agree that Nierotko blocks the Government's argument that the "wages paid" formulation in 26 U. S. C. §§ 3111(a) and 3301 has a dispositively plain meaning, we reject the Company's next contention. Because Nierotko read the 1939 "wages paid" language for benefits eligibility purposes to accommodate an allocation-back rule for backpay, the Company urges, the identical 1939 "wages paid" language for tax purposes must be read the same way. We do not agree that the latter follows from the former like the night, the day.
Nierotko dealt specifically and only with Social Security benefits eligibility, not with taxation. The Court's allocation holding in Nierotko in all likelihood reflected concern that the benefits scheme created in 1939 would be disserved by allowing an employer's wrongdoing to reduce the quarters of coverage an employee would otherwise be entitled to claim toward eligibility. No similar concern underlies the tax provisions. Although Social Security taxes are used to pay for Social Security benefits in the aggregate, there is no direct relation between taxes and benefits at the level of an individual employee. As the Company itself acknowledges, "Social Security tax 'contributions,' unlike private pension contributions, do not create in the contributor a property right to benefits against the government, and wages rather
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