Cite as: 532 U. S. 200 (2001)
Opinion of the Court
§ 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. § 414, 60 Stat. 990-991. Congress also used identical "wages paid" language in redefining the FICA and FUTA wage bases for tax purposes. § 412, 60 Stat. 989. Relying on the presumption that § 209(a), as amended, incorporated Nierotko's construction of § 209(g), see Cannon v. University of Chicago, 441 U. S. 677, 696-699 (1979), and observing that Congress redefined the wage bases for taxation to "confor[m] with the changes in section 209(a)," S. Rep. No. 1862, 79th Cong., 2d Sess., 36 (1946); H. R. Rep. No. 2447, 79th Cong., 2d Sess., 35 (1946), the Company urges that the amended benefits and tax provisions codified Nierotko's backpay allocation rule.
We are unpersuaded. Even assuming that the benefits provision, § 209(a), is properly construed as incorporating Nierotko's reading of § 209(g), we think the "confor[mity]" Congress sought to achieve between the tax and benefits provisions, S. Rep. No. 1862, supra, at 36; H. R. Rep. No. 2447, supra, at 35, had nothing to do with Nierotko's treatment of backpay. The Committee Reports make clear that Congress' purpose in amending the FICA and FUTA wage bases 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." S. Rep. No. 1862, supra, at 35 (emphasis added); H. R. Rep. No. 2447, supra, at 35 (emphasis added). It is with respect to this rule—measuring "wages" based on "the amount paid during the calendar year"—that Congress sought conformity between the Title 26 tax provisions and the Title 42 benefits provision. See S. Rep. No. 1862, supra, at 36 (tax wage base), 37 (benefits wage base); H. R. Rep. No. 2447, supra, at 35 (tax wage base), 36 (benefits wage base). Far from indicating an intent to codify Nierotko, those Reports suggest that Congress, if it considered
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