For several decades, the battle has raged over whether an individual is an employee or independent contractor for payroll tax purposes. In 1978, Congress attempted to clarify the situation by protecting most employees from a retroactive finding that an employer-employee relationship existed and by temporarily freezing the common law definition of employee.
"Independent Contractor or Employee?,"
Agricultural Law Digest: Vol. 7
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol7/iss3/1