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subsection would be entitled to notice of the existence of such
relief in accordance with subsection (e)(1), while other
potentially eligible taxpayers would not be entitled to such
notice. It is difficult to conceive that Congress intended such
a bifurcated notice provision.
The history of the enactment of section 530 confirms that
Congress did not intend section 530(a) to apply in the case of a
statutory employee. H. Rept. 95-1748 (1978), 1978-3 C.B. (Vol.
1) 629, is the report of the Committee on Ways and Means (the
committee) that accompanied H.R. 14159, 95th Cong., 2d Sess.
(1978), the text of which was generally followed by the
conference committee in formulating the conference agreement that
was enacted as section 530 of the Revenue Act of 1978, Pub. L.
95-600, 93 Stat. 2885. See H. Conf. Rept. 95-1800 (1978), 1978-3
C.B. (Vol. 1) 521, 605. In H. Rept. 95-1748 at 3 (1978), supra,
1978-3 C.B. at 631, the committee reports: “With certain limited
statutory exceptions, the classification of particular workers or
classes of workers as employees or independent contractors (self-
employed persons) for purposes of Federal employment taxes must
be made under common law rules.” The committee states as
reasons for a change in the law (1) increased enforcement by the
Internal Revenue Service (IRS) of the employment tax laws and
(2) complaints by taxpayers that proposed reclassifications
by the IRS involve a change of position by the IRS in
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