Rev. Rul. 78-284
Rev. Rul. 78-284; 1978-2 C.B. 253
- Cross-Reference
26 CFR 31.3121(d)-1: Who are employees.
(Also Sections 3306, 3401, 7805; 31.3306(i)-1, 31.3401(c)-1,
301.7805-1.)
- Code Sections
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
The Internal Revenue Service has been asked to reconsider the distinctions made in Rev. Rul. 75-243, 1975-1 C.B. 322, between the facts in that Revenue Ruling and the facts in Rev. Rul. 65-188, 1965-2 C.B. 390.
Rev. Rul. 75-243 holds on the basis of facts stated therein that interviewers are employees for Federal employment tax purposes. Several factors are listed distinguishing that ruling from Rev. Rul. 65-188, which holds that interviewers are not employees.
Rev. Rul. 65-188 implies that individual interviewers of the type described therein will never be considered employees. Upon reconsideration it is concluded that the issuance of Rev. Rul. 75-243 effectively limited Rev. Rul. 65-188.
Accordingly, pursuant to the authority provided by section 7805(b) of the Internal Revenue Code of 1954, Rev. Rul. 75-243 will be applied without retroactive effect with respect to wages paid before July 1, 1975.
- Cross-Reference
26 CFR 31.3121(d)-1: Who are employees.
(Also Sections 3306, 3401, 7805; 31.3306(i)-1, 31.3401(c)-1,
301.7805-1.)
- Code Sections
- LanguageEnglish
- Tax Analysts Electronic Citationnot available