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interpreting how the common law rules apply to their workers or
industry. Id. at 3-4, 1978-3 C.B. (Vol. 1) at 631-632. The
committee describes H.R. 14159, supra, as follows:
The bill provides an interim solution for
controversies between the Internal Revenue Service and
taxpayers involving whether certain individuals are
employees under interpretations of the common law by –-
(1) terminating certain employment tax liabilities
for periods ending before January 1, 1979,
(2) allowing taxpayers, who had a reasonable basis
for not treating workers as employees in the past, to
continue such treatment without incurring employment
tax liabilities for periods ending before January 1,
1980, while the committee works on a comprehensive
solution, and
(3) prohibiting the issuance of Treasury
regulations and Revenue Rulings on common law status
before 1980.
Id. at 4, 1978-3 C.B. (Vol. 1) at 632.
As evidenced by H. Rept. 95-1748 (1978), supra, the purpose
of H.R. 14159, supra, was to provide an interim solution to
controversies over common law employment status by, in part,
allowing taxpayers who had a reasonable basis for not treating
workers as employees under the traditional common law tests to
continue to do so, while Congress worked on a comprehensive
solution to the common law classification problem. There is no
suggestion in H. Rept. 95-1748, supra, of any controversy
concerning the classification of workers as statutory employees
that required any solution (interim or comprehensive) by
Congress. It is, therefore, a fair inference that the reasonable
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