United States v. Cleveland Indians Baseball Co., 532 U.S. 200, 19 (2001)

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218

UNITED STATES v. CLEVELAND INDIANS BASEBALL CO.

Opinion of the Court

effect that is compatible with the rest of the law." United Sav. Assn. of Tex. v. Timbers of Inwood Forest Associates, Ltd., 484 U. S. 365, 371 (1988). The Company's examples leave little doubt that the Government's rule generates a degree of arbitrariness in the operation of the tax statutes. But in Nierotko's context, an inflexible rule allocating back-pay to the year it is actually paid would never work to the employee's advantage; it could inure only to the detriment of the employee, counter to the thrust of the benefits eligibility provisions.14 In this case, by contrast, there is no comparable structural unfairness in taxation. The Govern-ment's rule sometimes disadvantages the taxpayer, as in this case. Other times it works to the disadvantage of the fisc, as the Company's examples show. The anomalous results to which the Company points must be considered in light of Congress' evident interest in reducing complexity and minimizing administrative confusion within the FICA and FUTA tax schemes. See supra, at 214. Given the practical administrability concerns that underpin the tax provisions, we cannot say that the Government's rule is incompatible with the statutory scheme. The most we can say is that Congress intended the tax provisions to be both efficiently administrable and fair, and that this case reveals the tension that sometimes exists when Congress seeks to meet those twin aims.

D

Confronted with this tension, "we do not sit as a committee of revision to perfect the administration of the tax laws." United States v. Correll, 389 U. S. 299, 306-307 (1967). In-14 The SSA has interpreted its regulation governing "[b]ack pay under a statute," 20 CFR § 404.1242(b) (2000), to allow the employee to choose whether to allocate the backpay to the year it is paid or to the year it should have been paid. Social Security Administration, Reporting Back Pay and Special Wage Payments to the Social Security Administration 2, Pub. 957 (Sept. 1997).

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