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explicitly provided by section 31.3121(b)(20)-1(a), Employment
Tax Regs., and implicitly provided by section 3121(b)(20) itself.
Respondent interprets the term “depends solely” in the regulation
to mean that section 3121(b)(20) excludes from “employment”
services performed for any additional payment that does not
depend on the amount of the catch. Respondent interprets the
term “proceeds” to include proceeds after subtraction of
operating expenses. We agree with respondent.
Statutory construction begins with the language of the
relevant statute. Consumer Prod. Safety Commn. v. GTE Sylvania,
Inc., 447 U.S. 102, 108 (1980); Fincher v. Commissioner, 105 T.C.
126, 133-134 (1995). We may use legislative history to clarify
an ambiguous statute. Patterson v. Shumate, 504 U.S. 753, 761
(1992); Canada Life Assurance Co. v. Converium Ruckversicherung
(Deutschland) AG, 335 F.3d 52, 57 (2d Cir. 2003); Fincher v.
Commissioner, supra; City of New York v. Commissioner, 103 T.C.
481, 489 (1994), affd. 70 F.3d 142 (D.C. Cir. 1995). When a
statute is ambiguous, the Court must find the interpretation that
can most fairly be said to be embedded in the statute, in the
sense of being most harmonious with its scheme and with the
general purposes that Congress manifested. NLRB v. Lion Oil Co.,
352 U.S. 282, 297 (1957). Reports by the Senate Committee on
Finance are an authoritative source for legislative intent.
Thornburg v. Gingles, 478 U.S. 30, 44 (1986); Garcia v. United
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