220
Scalia, J., concurring in judgment
regardless of when those wages were earned or should have been paid. Rev. Rul. 89-35, 1989-1 Cum. Bull. 280; Rev. Rul. 78-336, 1978-2 Cum. Bull. 255. We need not decide whether the Revenue Rulings themselves are entitled to deference. In this case, the Rulings simply reflect the agency's longstanding interpretation of its own regulations. Because that interpretation is reasonable, it attracts substantial judicial deference. Thomas Jefferson Univ. v. Shalala, 512 U. S. 504, 512 (1994). We do not resist according such deference in reviewing an agency's steady interpretation of its own 61-year-old regulation implementing a 62-year-old statute. "Treasury regulations and interpretations long continued without substantial change, applying to un-amended or substantially reenacted statutes, are deemed to have received congressional approval and have the effect of law." Cottage Savings Assn. v. Commissioner, 499 U. S. 554, 561 (1991) (citing Correll, 389 U. S., at 305-306).
* * *
In line with the text and administrative history of the relevant taxation provisions, we hold that, for FICA and FUTA tax purposes, back wages should be attributed to the year in which they are actually paid. Accordingly, the judgment of the United States Court of Appeals for the Sixth Circuit is reversed.
It is so ordered.
Justice Scalia, concurring in the judgment.
If I believed that the text of the tax statutes addressed the issue before us, I might well find for the respondent, giving that text the same meaning the Court found it to have in the benefits provisions of the Social Security Act. See Social Security Bd. v. Nierotko, 327 U. S. 358, 370, and n. 25 (1946). The Court's principal reason for assigning the identical language a different meaning in the present case—
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