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    UNITED STATES COURT OF APPEALS

    FOR THE NINTH CIRCUIT

    FIOR D'ITALIA, INC.,
    Plaintiff-counter-
                                                         No. 99-16021
    defendant-Appellee,
                                                         D.C. No.
    v.                                                    CV-97-04613-CAL
    UNITED STATES OF AMERICA,
                                                         OPINION
    Defendant-counter-
    claimant-Appellant.

    Appeal from the United States District Court
    for the Northern District of California
    Charles A. Legge, District Judge, Presiding

    Argued and Submitted
    March 15, 2000--Berkeley, California

    Filed March 7, 2001

    Before: Alex Kozinski, Andrew J. Kleinfeld and
    M. Margaret McKeown, Circuit Judges.

    Opinion by Judge Kozinski;
    Dissent by Judge McKeown

    _________________________________________________________________


    COUNSEL

    Jeffrey R. Meyer, Attorney for the Department of Justice Tax
    Division, Washington, D.C., for the appellant.

    Tracy J. Power, Power & Power, Arlington, Virginia, for the
    appellee.

    Peter G. Kilgore, for amicus curiae National Restaurant Asso-
    ciation in support of Appellee.

    _________________________________________________________________

    OPINION

    KOZINSKI, Circuit Judge.

    In a dispute involving a restaurant's share of Social Secur-
    ity taxes on its employees' tip income, we explore the outer
    bounds of the IRS's power to make tax assessments.

    I

    Like most restaurants, Fior D'Italia employs waiters, table
    bussers, bartenders and others whose earnings come in part

                                   2882
    from tips left by customers. Although these tips are paid by
    customers directly to employees, federal law deems them to
    have been paid by the employer for purposes of FICA taxes.
    See I.R.C. SS 3101, 3111, 3121(a) & (q). This puts employers
    in an awkward position: They are "deemed" for purposes of
    tax law, to have paid large sums of money that they have
    never touched and whose exact amounts they have no way of
    ascertaining. See I.R.C. S 3121(q). 1 Yet employers need to
    know how much tip income employees receive in order to cal-
    culate their own FICA taxes and withhold appropriate
    amounts from the wage portion of the employees' compensa-
    tion, pursuant to I.R.C. S 3102.

    To make this information known to employers, tipped
    employees must submit monthly statements (usually on Form
    4070) reporting all tip earnings that qualify as wages under
    the statute. See I.R.C. S 6053(a); Treas. Reg. S 31.6053-1(a).
    Employers, in turn, must report to the government (on Form
    8027) their gross sales, charged tips and the tip amounts
    reported by employees. See I.R.C. S 6053(c)(1).

    The dispute before us arose because in 1991 and 1992, Fior
    D'Italia reported aggregate tips that were significantly less
    than the tips that appeared on its credit card charge slips.2 The
    Internal Revenue Service assessed Fior for additional FICA
    taxes on what it deemed was unreported tip income for those
    years. To determine what Fior owed, the IRS used a simple
    calculation: For each year, it divided total tips charged on
    credit cards by total credit card receipts, yielding an average
    tip rate of 14.49% and 14.29% for 1991 and 1992, respec-
    _________________________________________________________________
    1 Some restaurants (not Fior) require all employees to pool cash tips for
    subsequent redistribution, in which case they do know, at least insofar as
    employees do not pocket some of the tips before pooling the rest. See 330
    West Hubbard Restaurant Corp. v. United States, 203 F.3d 990, 993 (7th
    Cir. 2000).
    2 For 1991, disclosed total charged tips were $364,786, while total tips
    reported by employees were $247,181. For 1992, the numbers were
    $338,161 charged and $220,845 reported.

                                   2883
    tively. It then applied this "tip rate" to the restaurant's gross
    receipts to get a presumed tip total for the year. The IRS
    assessed Fior additional FICA taxes based on the difference
    between its presumed total and the amount of tips Fior's
    employees had reported.3 The IRS did not readjust the FICA
    or income tax liability of the various employees who may
    have understated tip income on their 4070 forms.

    Fior challenged the assessment method in district court,
    arguing that it exceeded the IRS's authority. The district court
    agreed, Fior D'Italia, Inc. v. United States, 21 F. Supp. 2d
    1097 (N.D. Cal. 1998), and the government appeals.

    II

    [1] Because we must decide whether the IRS's assessment
    is valid, we begin by examining what exactly the IRS is
    assessing. Section 3111 imposes on every employer a tax
    equal to a percentage of "the wages . . . paid by him with
    respect to employment." I.R.C. S 3111(a). These wages are
    defined to include "tips received by an employee in the course
    of his employment." I.R.C. S 3121(q). But Congress did not
    treat all tips as taxable wages for this purpose. In section
    3121(a)(1), it excluded all remuneration from the employer
    (salary plus tips) that exceeds the Social Security wage base
    for that year.4 In section 3121(a)(12)(B), it excluded all cash
    tips received by an employee if that amount was less than $20
    in a given month. These latter two provisions are often
    described as defining the "wages band" outside of which tip
    income is not taxed. See Bubble Room, Inc. v. United States,
    159 F.3d 553, 555-56 (Fed. Cir. 1998) (Bubble Room II). For
    the IRS's aggregate assessment method to precisely equal the
    tips on which the employer's FICA tax is calculated, the cash
    tipping rate must be exactly the same as the tipping rate on
    _________________________________________________________________
    3 The IRS concluded that unreported wages totaled $156,545 in 1991
    and $147,529 in 1992.
    4 This base was $53,400 in 1991 and $55,500 in 1992.

                                   2884
    charge slips, and total tips received must be distributed among
    employees so that none falls outside the wages band.

    [2] Neither condition will hold true in most cases. First,
    experience shows that charged tips generally exceed cash tips.
    See Yukimura v. Commissioner, 43 T.C.M. (CCH) 467, 470
    (1982). One can think of many reasons why this would be so.
    Spending credit is easier than spending cash, because actual
    payment is deferred. Also, people dining on expense accounts
    generally pay with credit cards, and spending someone else's
    credit is even easier than spending one's own. Then there is
    the convenience of being able to write a tip in precisely the
    amount one deems appropriate. People paying in cash, how-
    ever generous they may feel, are limited by the amount actu-
    ally in their wallets and the need to keep some cash until their
    next visit to Gringott's. Applying the charged tip rate to cash
    receipts will thus tend to overestimate the cash tips actually
    paid. And charged tips paid to employees may be less than
    appears on the credit card receipts, because some employers
    pass on the three percent fee assessed by the credit card com-
    panies. See Bubble Room, Inc. v. United States, 36 Fed. Cl.
    659, 663 (1996) (Bubble Room I), rev'd , Bubble Room II, 159
    F.3d 553.

    [3] The assumption that all tip income falls within the
    wages band is even more problematic because Fior's employ-
    ees, like those of many other restaurants, engage in tip shar-
    ing. Waiters receive tips from the customers and then share
    them with table bussers, bartenders and other employees.
    Much like tips left by the customer, the exact amount shared
    with others depends on the waiter's generosity and his evalua-
    tion of how much other employees contributed to customer
    satisfaction. Looking only at the aggregate tips collected, we
    cannot tell how many table bussers made less than $20 in
    indirect tips per month for some or all of the periods in question.5
    _________________________________________________________________
    5 While $20 in tips per month is not very much, employees who start
    employment, leave employment, or take vacation or sick leave within a
    particular month may well earn less than that.

                                   2885
    Nor is there any way of knowing how many waiters and hosts
    received salaries plus tips exceeding the Social Security wage
    base--something we cannot rule out for an upscale restaurant
    like Fior D'Italia.

    While an employer may be aware that reported tips are less
    than actual charged tips, it cannot be sure that employees are
    understating tips in their 4070 forms. Some or all of the dis-
    crepancy could be explained by the fact that employees are
    not required to report tips falling outside the wages band.
    Even if the employer suspects that some employees are under-
    stating their tip income, it has no way of knowing who is
    underreporting or by how much. Restaurants cannot force
    waiters to divulge how much they have actually received in
    tips, and how those amounts were shared with other employ-
    ees. Nor are employees likely to volunteer such information,
    because they would be admitting that they committed tax
    fraud by understating their tip income on the IRS form they
    submitted to the employer.

    The IRS is unimpressed. It believes itself empowered to use
    any rational method for assessing the tax; the difficulties the
    employer raises can be considered in determining the precise
    amount of tax actually owed. If the assessment is valid, the
    burden shifts to the taxpayer to prove the amount (if any) by
    which the assessment overstates the tax owed. The question
    remains whether the assessment is valid.

    III

    The IRS's authority to make assessments is a very powerful
    tool. By making a valid assessment, the IRS shifts to the tax-
    payer the burden of proving that it does not owe the amount
    of tax the IRS has assessed it. If the taxpayer cannot persuade
    a trier of fact that the amount assessed is incorrect, the IRS
    wins and the taxpayer is required to pay that amount. See
    Palmer v. IRS, 116 F.3d 1309, 1312 (9th Cir. 1997). So long
    as the assessment is supported by a "minimal factual founda-

                                   2886
    tion," the IRS need not present any additional evidence; the
    risk of uncertainty falls on the taxpayer. Id .

    [4] In the income tax context, an assessment becomes even
    more powerful when coupled with the IRS's authority pursu-
    ant to I.R.C. S 446 to redefine the manner in which the tax-
    payer computes income. Section 446 has been interpreted as
    giving the IRS authority to make an assessment based on an
    estimate rather than a computation. See McQuatters v. Com-
    missioner, 32 T.C.M. (CCH) 1122, 1125 (1973). This means
    that, in making the assessment, the IRS need not rely on the
    actual records kept by the taxpayer. Where such records are
    inadequate, the IRS may make an educated guess as to how
    much tax is owed, and then put the burden on the taxpayer to
    prove it wrong.

    McQuatters also involved tip income but, unlike our case,
    it involved the income taxes of the employees who had actu-
    ally received the income. See also Mendelson v. Commis-
    sioner, 305 F.2d 519 (7th Cir. 1962). The tipped employees
    had failed to maintain adequate records of the tips they had
    received, and the courts held that the IRS was authorized to
    use an estimate in making its assessment. Because the
    employees should have maintained records of their income
    but failed to do so, it was deemed entirely appropriate to put
    the burden on them to prove that the IRS's estimate overstated
    their taxable income. See id. at 523 ("Obviously, where a tax-
    payer keeps no records disclosing his income, no method can
    be devised which will produce an exact result. The law does
    not require that much."); McQuatters, 32 T.C.M. (CCH) at
    1125 ("In the absence of adequate record keeping by petition-
    ers, [the IRS] was justified in reconstructing their tip income
    by an indirect method . . . .").

    The taxpayer in our case is in a very different position from
    the taxpayers in McQuatters and Mendelson. While each
    employee knows how much he receives in tips, the restaurant
    does not. Employees, moreover, have an obligation to main-

                                   2887
    tain records of their tip income and to accurately report such
    income to their employer on a monthly basis. The restaurant
    has no obligation to maintain records of tip income, except to
    the extent its employees report on Form 4070. Unlike the tax-
    payers in McQuatters and Mendelson, then, the taxpayer in
    our case did not fail to satisfy a legal duty imposed on it by
    the Internal Revenue Code, and thus did not give the IRS just
    cause for resorting to an estimate in constructing its assess-
    ment.

    Also, unlike the taxpayers in McQuatters and Mendelson,
    Fior is not in an inherently better position than the IRS to
    determine what its employees actually earned in tips. Quite
    the contrary: Fior lacks the IRS's power to audit its employ-
    ees and has no other means of forcing its employees to
    divulge how much tip income they earned during a given year.6
    Forcing the restaurant to prove that the estimate is wrong puts
    an impossible burden on it, making the already heavy pre-
    sumption that attaches to an IRS assessment virtually conclu-
    sive.

    We find this particularly troubling because the IRS's esti-
    mate has some serious flaws. As discussed above, the IRS's
    method for estimating cash tips likely overstates the amount
    of such tips received. See pp. 2885-86 supra. As to credit card
    tips, the IRS method fails to take into account the three per-
    cent fee imposed by the credit card companies which may be
    passed on to employees by the restaurant. Nor does the esti-
    mate make allowance for the statutory wages bands which
    limit the restaurant's FICA tax liability.
    _________________________________________________________________
    6 The government suggests that the employer could know exactly how
    much each employee makes in tips by adopting a tip-pooling arrangement.
    See note 1 supra. But adopting such an arrangement would alter the way
    a restaurant does business by undermining the incentive structures created
    by discretionary tip-sharing. It would be akin to saying that a restaurant
    must charge a fixed service charge in lieu of tips. Obviously, a restaurant
    cannot be required to change its business practices in order to avoid pay-
    ing taxes it doesn't owe.

                                   2888
    We can't ignore these inaccuracies on the theory that they
    will cancel each other out in the long run; they all overstate
    the base on which the FICA tax is calculated and thus will
    combine to overstate the amount the taxpayer owes. As Judge
    Plager noted in his dissent in Bubble Room II , "[t]hough it
    may be that the excess taxes assessed in this manner against
    the employer amount to a relatively small amount, a Govern-
    ment demand for taxes that are not owed is unlawful on its
    face and remains unlawful regardless of the amount at issue."
    159 F.3d at 569 (Plager, J., dissenting).

    We have held that the IRS's power to rely on estimates in
    making its assessment is not without bounds; rather, the IRS
    must use a "rational method for approximating the correct
    amount." Palmer, 116 F.3d at 1312. Where more accurate
    information does not exist because the taxpayer failed to
    maintain adequate records, or where the taxpayer has much
    better access to the information in question, we will generally
    defer to the IRS's decision as to what is a rational method for
    approximating the amount of tax due. But a case where the
    taxpayer has done everything the law requires of it, where the
    IRS's access to the relevant information is no worse (and
    probably much better) than the taxpayer's, and where the esti-
    mation method adopted by the government ignores the statu-
    tory limits on what is taxable, sorely tests the limits of that
    deference.

    [5] Fortunately, we need not decide whether the IRS has
    stretched deference to the breaking point because its assess-
    ment suffers from a more fundamental flaw: It rests on an
    estimate in circumstances where Congress has not authorized
    the IRS to use estimation as an assessment method. McQuat-
    ters and similar cases relied on I.R.C. S 446, which (as
    already discussed) gives the IRS broad authority to use esti-
    mates in making income tax assessments. But the IRS cannot
    rely on section 446 as authority for the assessment here
    because the section does not apply to the collection of FICA
    taxes.

                                   2889
    While acknowledging that section 446 is inapplicable, the
    Federal Circuit found it "informative" in concluding that the
    IRS is authorized to construct its assessment by means of esti-
    mation. Bubble Room II, 159 F.3d at 566. Like Judge Plager,
    we fail to understand "exactly how that section is informative
    with regard to the specific issue before us." Id. at 571 (Plager,
    J., dissenting). To the extent section 446 has any bearing at
    all, it suggests that the IRS here was not authorized to proceed
    by estimation. Congress obviously knew how to give the IRS
    the authority to use estimation in lieu of actual calculations,
    and just as clearly thought it necessary to say so explicitly
    when it wished to confer that power. Unlike our colleagues in
    the Bubble Room II majority, we do not believe such an
    important and sweeping power can be derived from the pen-
    umbras and emanations of the Internal Revenue Code.

    [6] The IRS points to another source of authority for its
    assessment, namely I.R.C. S 3121(q). This section provides
    that an employer is liable for its portion of FICA taxes even
    when "no statement including such tips is . . . furnished" or
    "the statement so furnished was inaccurate or incomplete."
    But this section doesn't help the government. All it says is
    that, where employees have not provided accurate tip infor-
    mation to the employer, and the IRS finds some other means
    of determining how much the employer owes, the employer
    must pay its share. Nothing in the text of section 3121(q)
    speaks to the method the IRS may use in making its assess-
    ment. In fact, section 3121(q) is worded so differently from
    section 446 that we cannot conclude they were meant to do
    the same work.

    The IRS points to the fact that section 3121(q) allows it to
    assess the employer even after the time for assessing the
    employee has passed. See Rev. Rul. 95-7, 1995-4 I.R.B. 44
    (Q&A 11).7 According to the IRS, this implicitly authorizes
    _________________________________________________________________
    7 The Code does this by providing that unreported tips "shall be deemed
    for purposes of subtitle F to be paid on the date on which notice and

                                   2890
    the use of estimates. The chain of reasoning goes something
    like this: If the IRS is allowed to assess the employer when
    it may no longer audit the employees, it will have no way to
    conduct the assessment except by estimation. Congress there-
    fore must have contemplated that the IRS would proceed by
    estimation in making the assessments.

    [7] We do not see this as a necessary implication. Rather,
    we read section 3121(q) as saying that the IRS need not also
    conduct an audit of the employer while it is auditing the
    records of individual employees. Congress doubtless under-
    stood that the only way the IRS can determine FICA taxes on
    tips is by examining the employees' records; there's no point
    in auditing the restaurant at the same time because it will have
    no record of tips, other than the information provided by the
    employees in their 4070 and 8027 forms. But, if the normal
    limitations period applied, the IRS might have to assess the
    employer before it finished auditing the employees. Section
    3121(q) solves this problem by keeping the period open
    indefinitely--which means for however long it takes to com-
    plete the audit of the restaurant's tipped employees.8

    [8] This does not mean that the IRS may assess the
    employer only if it also assesses each of its employees. Three
    other circuits have rejected this argument and, for reasons
    well expressed in those opinions, we reject it as well. See 330
    _________________________________________________________________
    demand for such taxes is made." I.R.C. S 3121(q). Thus, the limitations
    period for the assessment of the employer's FICA taxes only begins to run
    after notice and demand is made, even if the limitations period for the
    assessment of the employee's tax has expired.
    8 Tying the employer's liability to the audit period for its employees also
    avoids the anomaly that would arise from the fact that section 3121(q) pro-
    vides no time limit for assessing the employer for additional FICA taxes,
    making it theoretically possible that the employer could be assessed 10, 20
    or more years after the tax year in question. If employer assessments are
    tied to employee audits, the employer can only be assessed for however
    long it takes to conduct audits of its various tipped employees, plus a rea-
    sonable time thereafter.

                                   2891
    West Hubbard Restaurant Corp. v. United States , 203 F.3d
    990, 995 (7th Cir. 2000); Bubble Room II, 159 F.3d at 565;
    Morrison Restaurants, Inc. v. United States, 118 F.3d 1526,
    1529 (11th Cir. 1997). As the government correctly points
    out, the employer's portion of FICA is separate from the
    employee's, and the IRS need not collect the one as a condi-
    tion for collecting the other. Having audited an employee and
    determined the precise amount of FICA wages the employee
    has received, the IRS may then choose to assess only the
    employer, only the employee, or both. If the IRS cannot or
    will not assess the employee for additional FICA tax, this will
    not jeopardize its right to assess the employer. 9

    [9] That having been said, it does not follow that the IRS
    can dispense with auditing the employees' records or other-
    wise determining the amount each employee earned in tips.
    For the reasons explained, there is no way to determine the
    employer's FICA tax liability without making an employee-
    by-employee determination of the taxable tips each has
    earned. An aggregate assessment based on inaccurate esti-
    mates, as used by the IRS in this case, is simply not authorized.10
    _________________________________________________________________
    9 Accordingly, our holding is entirely consistent with those of the Sev-
    enth and Eleventh Circuits, both of which considered only whether the
    IRS must assess the employees prior to assessing the employer and not
    whether the IRS may rely upon aggregate estimates--the issue which is
    the fulcrum of our ruling. See 330 West Hubbard Restaurant Corp., 203
    F.3d at 994 ("On appeal, Coco Pazzo argues that the district court erred
    in holding that the IRS was authorized . . . to assess employer FICA taxes
    based on an aggregate estimate of the tip income received by its employ-
    ees without first determining the amount of under reporting by individual
    employees."); Morrison Restaurants, 118 F.3d at 1529 ("Morrison Restau-
    rants contends that, in view of Congress's silence, the IRS lacks statutory
    authority to assess the employer's share of FICA taxes without determin-
    ing the individual employees' unreported tips and crediting the employees
    with the employer's share of the tax."). The Federal Circuit's decision in
    Bubble Room II is another story.
    10 The dissent worries that the IRS won't be able to collect the employ-
    er's share of FICA taxes, because it can't audit every waiter at every res-
    taurant to determine the amount of under-reporting. See Dissent. Op. at

                                   2892
    While recognizing that "I.R.C. S 3121(q) does not fully
    address the question at issue here," the Federal Circuit never-
    theless found that the section "would . . . seem to imply that
    an indirect method may be used to calculate the amount of
    employer FICA tax in the absence of any better evidence."
    Bubble Room II, 159 F.3d at 565.11  The Federal Circuit
    derived this implication as follows: Section 3121(q) comes
    into play only where "no statement including such tips was so
    furnished (or to the extent that the statement so furnished was
    inaccurate or incomplete)." I.R.C. S 3121(q). Because the sec-
    tion applies where the employer's records are inadequate, the
    Federal Circuit reasoned, Congress must have known that the
    IRS would have no choice but to use an aggregate estimation
    method. See Bubble Room II, 159 F.3d at 565.

    Respectfully, we disagree with our colleagues. If the
    employer's records are inadequate, it is because its employees
    have failed to report all their tips. The direct and obvious way
    of determining the taxable tips actually received is for the IRS
    to audit the employees. Proceeding by aggregate estimate, and
    thereby forcing the employer to pay the price for its employ-
    ees' dereliction, is simply not the only (nor even the best) way
    the IRS may proceed. We therefore cannot agree that Con-
    gress must have had this in mind when it passed section
    3121(q).

    We are aware that auditing individual employees is much
    _________________________________________________________________
    2907. But if this turns out to be a problem, the IRS can solve it by promul-
    gating a regulation allowing it to assess restaurants using estimates. See p.
    2894-95 infra. Even without such a regulation, we are not convinced that
    the IRS must audit every waiter in order to ensure effective collection of
    the tax. As with other taxes, a vigorous enforcement program will encour-
    age waiters to report tips more accurately, for fear of suffering penalties
    if caught. Moreover, when it does audit waiters, the IRS can also assess
    the restaurant for its portion of the tax.
    11 The Federal Circuit used the term "indirect method" where we use the
    term "estimate." Both mean the same thing.

                                   2893
    more cumbersome than slapping the employer with assess-
    ments based on aggregate estimates. The fact remains that
    Congress authorized the IRS to use estimates in collecting
    income taxes but withheld such authority in collecting FICA
    taxes. By using an estimate--and particularly one that ignores
    the statutory wages bands--and putting on the employer an
    impossible burden in rebutting the estimated amount, the IRS
    has effectively increased the tax payable by the employer
    above that provided in the Internal Revenue Code. 12

    Nor is the IRS without recourse. If auditing individual
    employees proves too cumbersome, it can seek to have Con-
    gress extend its section 446 authority to the collection of
    FICA taxes. Or, it may proceed by regulation. I.R.C.
    S 6205(a)(1) speaks to this situation:

          If less than the correct amount of tax imposed by
          section 3101, 3111, 3201, 3221, or 3402 is paid with
          respect to any payment of wages or compensation,
          proper adjustments, with respect to both the tax and
          the amount to be deducted, shall be made, without
          interest, in such manner and at such times as the
          Secretary may by regulations prescribe.

    Id. (emphasis added). This provision seems to authorize the
    Secretary to give the IRS authority to make assessments based
    on aggregate estimates by promulgating a regulation to that
    _________________________________________________________________
    12 As the Court of Federal Claims rightly remarked:

          Even a substantially low reporting of cash tips . . . does not jus-
          tify allowing the IRS to shift its responsibility to the employer for
          policing the acknowledged problem of underreporting of tips by
          employees. It is the responsibility of the IRS to track down and
          collect unreported income. If the IRS wishes to shift its duty to
          employers to ensure proper compliance, it should do so through
          a congressional enactment and continued cooperation between
          restaurants and the IRS."

    Bubble Room I, 36 Cl. Ct. at 678 (Horn, J.).

                                   2894
    effect. But, before imposing such rough justice, the Secretary
    must follow the procedural requirements of notice-and-
    comment rulemaking.

    These are not idle steps. The rulemaking process, by its
    very design, encourages public scrutiny of an agency's pro-
    posed course of action. By giving notice of a proposed rule,
    the agency provides interested parties with the opportunity to
    express their views and bring their political influence to bear
    on the process. See 1 Kenneth Culp Davis & Richard J.
    Pierce, Jr., Administrative Law Treatise,S 6.7 (3d ed. 1994)
    (noting that rulemaking enhances the "political accountability
    of agency policy decisions adopted through the rulemaking
    process"); Bernard Schwartz, Administrative Law, S 4.16 (2d
    ed. 1984) ("Rulemaking provides the agency with a forum for
    soliciting the informed views of those affected in industry and
    labor before adopting a new policy.").

    The political process plays a particularly significant role in
    the arena of tax policy. Congress has delegated to the Secre-
    tary broad regulatory powers to adjust the legal obligations of
    taxpayers. See, e.g., I.R.C. S 6205(a)(1). But before the Secre-
    tary can give a regulation legal force, he must endure the scru-
    tiny of interested groups, legislative critics and the public at
    large. Congress maintains a particularly vigilant oversight
    through the Joint Committee on Taxation, whose large staff
    monitors and reports on the collection activities of the Depart-
    ment of the Treasury. See I.R.C. SS 8001, 8004, 8022.

    Indeed, Congress has blocked at least one of the IRS's
    recent efforts to enhance the collection of FICA taxes on cash
    tips. In 1993, the IRS promulgated a regulation that con-
    strained restaurants' ability to take advantage of a FICA tax
    credit by limiting the credit to the amount of tip income
    received and reported by the employee (as opposed to the
    amount of FICA taxes paid by the restaurant). See Treas. Reg.
    S 1.45B-1T (1994). The purpose of the regulation was to give
    employers an incentive for encouraging employees to report

                                   2895
    their tips. See, e.g., Fior d'Italia, 21 F. Supp. 2d at 1103-04
    (quoting Letter from Leslie B. Samuels, Assistant Secretary of
    the Treasury, to Senator Trent Lott (Mar. 30, 1994)).
    Responding to industry complaints, Congress rejected this
    incentive scheme in 1996 and provided that the tax credit
    would be available "without regard to whether such tips are
    reported under section 6053." I.R.C. S 45B(b)(1)(A).

    This episode demonstrates the difficulty the executive and
    the legislative branches have had in reaching common ground
    on the problem of collecting taxes on employee tips. This
    should surprise no one, given both the substantial amount of
    revenue involved and the serious administrative difficulties in
    determining the amounts employees receive in tips. In the
    wake of political setbacks, the IRS has tried to solve the prob-
    lem by assessing restaurants based only on the rough, and
    somewhat inflated, estimates that we have seen in this case.
    But before it can take such a significant step, it must obtain
    authorization directly from Congress or by exercising Trea-
    sury's own regulatory authority. Either path involves signifi-
    cant political checks on agency discretion, and we decline to
    assist the IRS in avoiding the public scrutiny such a process
    would entail.

    AFFIRMED.

    _________________________________________________________________

    McKEOWN, Circuit Judge, dissenting:

    The issue in this case is the authority of the Internal Reve-
    nue Service to use the aggregate method of assessment for the
    employer's share of Social Security taxes on unreported tip
    income. The separate issue of the accuracy of the assessment
    is not before us and the two concepts--authority and accuracy
    --should neither be confused nor mixed and matched. In
    affirming the district court's rejection of the aggregate
    approach, the majority creates a circuit split on a tax issue of

                                   2896
    national importance. Unlike Quidditch or Fizzing Whizbees,
    there is nothing magical about the IRS's assessment--the
    employer owes taxes on the unreported tip income and the
    IRS has simply devised a practical means of calculating the
    tip income. In view of our respect for the decisions of sister
    circuits in tax cases, our deference to the IRS in interpreting
    the tax code, and the logic and practicality of the aggregate
    method, I respectfully dissent.

    A. OTHER CIRCUITS.

    The question of whether the IRS is authorized to assess the
    employer's share of Federal Insurance Contribution Act
    ("FICA") taxes, commonly known as Social Security taxes,
    based on the aggregate method without first determining the
    amount of under-reporting by individual employees is one of
    first impression in this circuit. Three other circuits, however,
    have already addressed this issue, and all three have held that
    the tax code ("Code") authorizes the IRS to do so. See 330
    West Hubbard Restaurant Corp. v. United States, 203 F.3d
    990, 997 (7th Cir. 2000); Bubble Room, Inc. v. United States,
    159 F.3d 553, 568 (Fed. Cir. 1998) (Bubble Room II); Morri-
    son Restaurants, Inc. v. United States, 118 F.3d 1526, 1530
    (11th Cir. 1997); see also LIR Mgmt. Corp. v. United States,
    86 F. Supp. 2d 340, 346 (S.D.N.Y. 2000); Quietwater Entm't,
    Inc. v. United States, 80 F. Supp. 2d 1323 (N.D. Fla. 1999),
    rev'd in part, vacated in part without op., 220 F.3d 592 (11th
    Cir. 2000).

    The majority's position places the Ninth Circuit directly at
    odds with our sister circuits, which is of particular concern in
    this case, as "[u]niformity among Circuits is especially impor-
    tant . . . to ensure equal and certain administration of the tax
    system." Hill v. Comm'r, 204 F.3d 1214, 1217-18 (9th Cir.
    2000) (internal quotation marks and citations omitted). Until
    now, we have "hesitate[d] to reject the view of another cir-
    cuit" in this area. Id. (internal quotation marks and citations
    omitted).

                                   2897
    Three years ago the Eleventh Circuit was the first circuit to
    address the question before us. In Morrison Restaurants, the
    employer sought a refund and abatement of FICA taxes
    assessed on unreported employee tips. 118 F.3d at 1528. The
    employer argued that the IRS does not have the authority
    under 26 U.S.C. S 3121(q) to assess its share of FICA taxes
    on unreported tips on an aggregate basis without first deter-
    mining the under-reporting by individual employees and cred-
    iting their wage history accounts. Id. at 1529. This is precisely
    the position advocated by Fior d'Italia. The Eleventh Circuit
    rejected this argument, noting that S 3121(q)

          clearly states than an employer can be assessed for
          its share of FICA taxes on employee tips even if the
          employee fails to report all tips. It also suggests that
          the employer can be assessed its share of FICA taxes
          even when the individual employee's share is not
          determined.

    Id. (emphasis added). The court concluded:

          [W]e are unconvinced that Congress's silence can be
          construed to mean that an employer cannot be
          assessed its share of FICA taxes based on employ-
          ees' unreported tips in the aggregate without deter-
          mining the underreporting by the individual
          employees and crediting the individual employees'
          wage history accounts.

    Id. at 1529-30. The Eleventh Circuit deferred to the IRS's use
    of the aggregate method because its interpretation of the Code
    was reasonable. Id. at 1530.

    The next year, in Bubble Room II, 159 F.3d at 554, the Fed-
    eral Circuit similarly addressed whether the IRS has the
    authority to assess the employer's share of FICA taxes on
    unreported tips on an aggregate basis "without first determin-
    ing the under-reporting by the individual employees and then

                                   2898
    crediting their Social Security wage earnings records." The
    court concluded that the statutes authorize the IRS to do so:

          I.R.C. S 3121(q) expressly contemplates that the
          employer may be liable for its share of FICA taxes
          even if the records supplied by the employee are
          missing, inaccurate, or incomplete. Although not
          conclusive, S 3121(q) would thus seem to imply that
          an indirect method may be used to calculate the
          amount of employer FICA tax in the absence of any
          better evidence.

           However, I.R.C. S 3121(q) does not fully address
          the question at issue here--whether the particular
          indirect formula used by the IRS to estimate the
          [employer's] FICA tax liability was illegal. I.R.C.
          S 6201 speaks to this question. Under I.R.C.S 6201,
          the IRS is "authorized and required to make the
          inquiries, determinations, and assessments" neces-
          sary for all taxes imposed by the Code, "which have
          not been duly paid . . . in the manner provided by
          law." I.R.C. S 6201 implicitly authorizes the IRS to
          use an indirect formula in order to carry out the gen-
          eral power granted in I.R.C. S 6201. For example,
          the IRS would have to use an indirect formula to
          estimate the amount of FICA tax owed by an
          employer when there is no other way to "determine
          and assess" the wages deemed to have been paid by
          the employer.

    Id. at 565. The Federal Circuit concluded that the statutes
    authorize the IRS to use the aggregate method without first
    determining the individual employees' tip income. See id. at
    566-68.

    Most recently, in 330 West Hubbard Restaurant , 203 F.3d
    990 at 997, the Seventh Circuit addressed the issue and simi-
    larly concluded that the statutes authorize the IRS to assess

                                   2899
    the employer's share of FICA taxes based on the aggregate
    method without first determining the amount of under-
    reporting by individual employees. The Seventh Circuit was
    unequivocal:

          We conclude that [the employer] has failed to dem-
          onstrate that the IRS's aggregate method of collect-
          ing employer FICA taxes is an impermissible
          reading of the tax code. Accordingly, we uphold the
          IRS's interpretation of its authority to use the aggre-
          gate method of collecting FICA taxes.

    Id. at 997.

    Every circuit court that has addressed the aggregate assess-
    ment issue has come to the opposite conclusion from the
    majority. The majority's attempt to avoid the weight of circuit
    authority by suggesting that its position is somehow in line
    with that of 330 West Hubbard Restaurant and Morrison Res-
    taurants is transparently unsuccessful. See Maj. Op. at 2892
    n.9 ("our holding is entirely consistent with those of the Sev-
    enth and Eleventh Circuits"). As noted above, both the Sev-
    enth and Eleventh Circuits held that the IRS has the authority
    to use the aggregate method with respect to unreported tip
    income without determining the under-reporting by individual
    employees and crediting their wage history accounts. See 330
    West Hubbard Restaurant, 203 F.3d at 994, 997; Morrison
    Restaurants, 118 F.3d at 1529-30. Although the majority
    agrees that the IRS need not assess the employees in order to
    assess the employer, the majority concludes that the IRS may
    not rely on the aggregate method and must audit  the employ-
    ees. See Maj. Op. at 2892 & n.9. Requiring an audit is simply
    another way of saying that the IRS cannot estimate and that
    the only way the IRS can assess taxes on unreported or under-
    reported tips is to undertake an individual accounting of
    employees. This view can hardly be viewed as "entirely con-
    sistent" with that of the Seventh and Eleventh Circuits. The
    IRS's authority to use the aggregate method was at the heart

                                   2900
    of the cases in those circuits. The majority's recharacteriza-
    tion can only pretend consistency with these cases.

    B. THE IRS'S INTERPRETATION IS REASONABLE.

    The Supreme Court has instructed that we must defer to an
    agency's interpretation of its statutes and that our review is
    restricted to determining whether that interpretation is reason-
    able. See Chevron U.S.A. Inc. v. Natural Resources Def.
    Council, Inc., 467 U.S. 837, 843 (1984) ("[I]f the statute is
    silent or ambiguous with respect to the specific issue, the
    question for the court is whether the agency's answer is based
    on a permissible construction of the statute."); United States
    v. Nat'l Bank of Commerce, 472 U.S. 713, 730 (1985) ("The
    IRS's understanding of the terms of the Code is entitled to
    considerable deference."); Bob Jones Univ. v. United States,
    461 U.S. 574, 596 (1983) ("this Court has long recognized the
    primary authority of the IRS . . . in construing the Internal
    Revenue Code"). We have likewise limited our review of IRS
    interpretations of the Code. See Walthall v. United States, 131
    F.3d 1289, 1297 (9th Cir. 1997) (concluding that where the
    IRS's interpretation is reasonable, "[w]e must . . . show the
    IRS interpretation substantial deference"); Durando v. United
    States, 70 F.3d 548, 550 (9th Cir. 1995) ("Courts give defer-
    ence to IRS rulings and interpretations of the Code."); Haw-
    kins v. United States, 30 F.3d 1077, 1082 (9th Cir. 1994)
    (recognizing "the well-settled rule that an agency's interpreta-
    tion of a statute is entitled to deference unless it contradicts
    the statute's plain meaning").

    In reviewing the IRS's interpretation of the Code, we "need
    not find that the agency construction [is] the only one it per-
    missibly could have adopted to uphold the construction, or
    even the reading that [we] would have reached if the question
    initially had arisen in a judicial proceeding." Chevron, 467
    U.S. at 843 n.11; accord Walthall, 131 F.3d at 1297 (conclud-
    ing that although "[t]he statute is not susceptible only to the
    [taxpayers'] interpretation . . . the IRS's interpretation . . . is

                                   2901
    reasonable" and "[w]e must therefore show the IRS interpre-
    tation substantial deference"). Moreover, we owe deference to
    the IRS's interpretation of the Code even absent a formal IRS
    rule. See Alexander v. Glickman, 139 F.3d 733, 736 (9th Cir.
    1998) ("We owe deference to the agency's interpretation of
    the statute even absent a formal agency rule interpreting the
    statute.").

    The IRS's interpretation of the statutes at issue here--that
    is, its conclusion that the statutes permit it to use the aggre-
    gate method--is reasonable in light of the statutory language.
    Nothing in the statutes or regulations requires the IRS to
    determine the amount of unreported tips before assessing the
    employer's FICA tax liability, and nothing in the statutes or
    regulations prohibits the IRS from using the aggregate
    method. Rather, the IRS's use of the aggregate method is
    entirely consistent with the statutes and regulations and there-
    fore is entitled to substantial deference. A brief review of the
    relevant Code sections reveals that the Code does not require
    or bar any method, but leaves selection of the method to the
    agency.

    Section 3111 imposes a FICA tax on employers that is
    computed as a percentage of wages paid by the employer to
    its employees. 26 U.S.C. S 3111; 26 C.F.R.SS 31.3111-1,
    31.3111-4. "Wages" includes all tips received by employees
    except those that amount to less than $20 in any calendar
    month. 26 U.S.C. S 3121(a)(12)(B), (q); 26 C.F.R.
    S 31.3121(a)(12)-1. Section 3121(q) requires employers to
    pay the S 3111 taxes on the total amount of tips and other
    remuneration, up to the Social Security wage base. See 26
    U.S.C. S 3121(a)(1). As the Federal Circuit recognized,

          [i]n the case of the employee FICA tax, the employer
          need only consider those tips that "are included in a
          written statement furnished by the employee to the
          employer pursuant to section 6053(a)." Unlike the
          employee FICA tax, however, there is no parallel

                                   2902
          provision which limits the employer's FICA tax lia-
          bility to tips that are included in the written state-
          ment furnished by the employee.

    Bubble Room II, 159 F.3d at 556 (quoting 26 U.S.C.
    S 3102(c)) (emphasis added).

    Although the statutes do not directly address whether the
    IRS has the authority to make aggregate assessments with
    respect to unreported tips, see Maj. Op. at 2890-91, they are
    certainly broad enough to permit the IRS to do so. In fact, it
    is precisely the statutes' silence that requires Chevron defer-
    ence. See Chevron, 467 U.S. at 843. In particular, S 3121(q)
    provides that, even in cases where employees do not provide
    the employer with tip statements under 26 U.S.C.S 6053(a)
    or where the statements are inaccurate or incomplete, the IRS
    may issue a notice and demand for employer FICA taxes. See
    26 U.S.C. S 3121(q). The statute does not  suggest, let alone
    require, that the IRS must first audit the employees to deter-
    mine the amount of unreported tips.

    This statutory silence is buttressed by S 6201's express del-
    egation authorizing the IRS to determine and assess the
    amount of FICA taxes imposed by S 3111. See 26 U.S.C.
    S 6201. Specifically, S 6201(a) permits the IRS to "make the
    inquiries, determinations, and assessments of all taxes . . .
    imposed by this title." 26 U.S.C. S 6201(a). It is up to the IRS
    to choose the method, so long as reasonable, and it is reason-
    able for the IRS to conclude that the authority to determine
    and assess taxes includes the authority to use the aggregate
    method to assess the employer's taxes on unreported tips.
    Indeed, the IRS uses estimation methods in other contexts--
    specifically, to determine the amount of tips received by
    employees and assess a FICA tax against them under 26
    U.S.C. S 446(b). Like S 6201(a), S 446(b) does not specifi-
    cally authorize estimates, but S 446(b) has been interpreted to
    permit the IRS to use estimates to determine tax assessments.
    See Bubble Room II, 159 F.3d at 557-58. The majority posits

                                   2903
    that use of estimates with respect to employees is permissible
    but not so with employers. See Maj. Op. at 2887-88. This
    dichotomy overlooks the fact that employers and employees
    have independent tax obligations with respect to tips. And,
    although employers arguably have a more difficult burden
    than employees in documenting the actual amount of tips, the
    implementation of estimates is a judgment best left to the IRS,
    not the court. The majority's approach tramples the deference
    owed to the IRS.

    The IRS's interpretation of the statutes is also consistent
    with S 3111's imposition of a single tax on the employer
    based on the aggregate tips and other wages received by its
    employees. See 26 U.S.C. S 3111(a)-(b); Bubble Room II, 159
    F.3d at 566 ("[T]he employer FICA tax imposed by I.R.C.
    S 3111 is expressed in terms of the employees' aggregate tip
    income."). Similarly, the limitations period for the assessment
    of employer FICA taxes is consistent with the conclusion that
    the IRS need not audit employees before assessing the
    employer; the limitations period does not begin to run until
    after notice and demand by the IRS under S 3121(q), even if
    the limitations period for assessing employees has run. See
    Rev. Rul. 95-7, 1995-4 I.R.B. 44 (Q&A 11). In other words,
    because the IRS can assess the employer even after it may no
    longer audit the employees, the statute implicitly authorizes
    the use of estimates. Although, as the majority points out,
    other interpretations of the statute are possible, see Maj. Op.
    at 2890-91, to be reasonable, the IRS's interpretation need not
    rule out alternatives.

    Congressional action in recent years suggests that Congress
    believes that the IRS has the authority to use the aggregate
    method as well. In 1998, Congress passed a law that prohib-
    ited the IRS from "threaten[ing] to audit[a] taxpayer in an
    attempt to coerce the taxpayer into entering a Tip Reporting
    Alternative Commitment [TRAC] Agreement." Internal Reve-
    nue Service Restructuring and Reform Act of 1998, Pub. L.
    No. 105-206, S 3414, 112 Stat. 685, 755 (July 22, 1998).

                                   2904
    Under the TRAC program, the employer agrees to educate its
    employees about tax reporting, establish procedures to ensure
    accurate tip reporting, and fulfill various federal tax require-
    ments; in return, the IRS agrees to base the employer FICA
    tax liability solely on reported tips and any unreported tips
    discovered during an IRS audit of an employee. See H.R.
    Conf. Rep. No. 105-599 at 274 (1998); S. Rep. No. 105-174
    at 75 (1998); H.R. Rep. No. 105-364 (Pt. 1) at 73 (1997). The
    TRAC program is a special initiative that limits the employ-
    er's liability to actual rather than estimated tips. But, in mak-
    ing sure that TRAC is not used as a cudgel, Congress
    acknowledged the IRS's power to make aggregate calcula-
    tions of employer tax obligations, before or without making
    determinations with respect to individual employees.

    As the majority concedes, the IRS need not assess each
    employee before it can assess the employer. See Maj. Op. at
    2891. The majority stresses, rather, that the IRS need only
    audit each employee before assessing the employer. See Maj.
    Op. at 2892 & n.9. But, as the majority recognizes, employer
    and employee tax obligations are completely separate. See
    Maj. Op. at 2892. One has nothing to do with the other.
    Although the employer and employee may be bound together
    through an employment relationship, their tax obligations
    arise separately. See Bubble Room II, 159 F.3d at 565 ("We
    read SS 3101 and 3111 as imposing a separate and distinct tax
    liability on employers.").1 Where the wages fall within the
    wages band, the employer must pay taxes on them, regardless
    _________________________________________________________________
    1 Many of Fior d'Italia's arguments against use of the aggregate method
    focus on employees; for example, incentives with respect to employee tip-
    reporting and crediting of employee Social Security accounts. But the
    employer and employee tax obligations are separate and not completely
    parallel. Whether employees report their tips and receive Social Security
    credit is not at issue here. If employees do not receive Social Security
    credit for all of their income, it is because they under-reported their
    income--not because of the aggregate method of assessing employer
    FICA taxes.

                                   2905
    of whether the employees reported them. See 26 U.S.C.
    S3121(q).

    The employer's independent tax obligation resonates in the
    structure and text of the Code. The respective employer and
    employee tax obligations are set forth in different subchap-
    ters. The employer's obligation is set forth inS 3111; the
    employees' obligation is set forth in S 3101. As previously
    noted, the employer's duty to collect and remit the employees'
    share of FICA taxes applies only with respect to reported tips
    --the employer's duty is not so limited. See 26 U.S.C.
    S 3102(c)(1), 3121(q). Finally, as discussed above, the limita-
    tions periods for the two tax obligations are different. See 26
    U.S.C. S 3121(q).

    The majority makes much of the IRS's lack of specific reg-
    ulatory authority to use the aggregate method. But, as noted
    earlier, the IRS does not need to adopt a regulation in order
    to benefit from the deference owed to its interpretation of the
    Code. The majority also projects the image of a rogue IRS
    exercising its muscle to collect employer taxes on unreported
    tips, trampling on restaurants' rights and ignoring basic pro-
    cess. This characterization obscures the congressional dictate
    to tax all wages, specifically including unreported tips, and
    ignores the fact that the IRS's method is based on justifiable
    projections, not "thin air" estimates.

    The majority also intimates that Congress tried to put the
    brakes on the IRS's effort to collect employer taxes on tips.
    An examination of recent legislation dispels this notion. Code
    S 45B generally allows an income tax credit to an employer
    for employer FICA taxes paid with respect to employee tips.
    See 26 U.S.C. S 45B. In 1996, Congress amended S 45B to
    clarify that the tax credit is available for employer FICA taxes
    paid on all tips, regardless of whether the employees reported
    the tips. See 26 U.S.C. S 45B(b)(1)(A), as amended by Small
    Business Job Protection Act of 1996, Pub. L. No. 104-188,
    S 1112(a), 110 Stat. 1755, 1759 (1996). The majority reads

                                   2906
    this amendment as "demonstrat[ing] the difficulty the execu-
    tive and the legislative branches have had in reaching com-
    mon ground on the problem of collecting taxes on employee
    tips." See Maj. Op. at 2896. But, rather than a rebuke of "the
    IRS's recent efforts to enhance the collection of FICA taxes
    on cash tips," as the majority suggests, Maj. Op. at 2895, the
    amendment merely confirms that the employer's tax obliga-
    tion is completely separate from the employees' obligation.
    And the amendment does more--it confirms that the IRS may
    impose taxes on all tips and that the employer may benefit
    from a tax credit on those tips, whether reported or not.

    C. PRACTICALITY OF AGGREGATE  METHOD.

    The majority's policy arguments against the aggregate
    method are just that--the court making policy. Equally avail-
    ing practical and policy considerations support the IRS's
    approach and weigh against the majority's position. For
    example, the majority's approach effectively prohibits the IRS
    from assessing the employer's share of FICA taxes with
    respect to unreported tips because the IRS cannot possibly
    audit all tipped employees to determine the degree of under-
    reporting. See Bubble Room II, 159 F.3d at 567 ("[A]s a prac-
    tical matter, the IRS lacked the resources necessary to audit
    each of the [employer's] tipped employees to determine the
    unreported tip income of each tipped employee."). The major-
    ity's approach thereby invites employers and employees alike
    to evade their statutory tax obligations. See id. ("[R]equiring
    the IRS to make an assessment against each employee for
    employee FICA taxes on unreported tips before the IRS could
    make an assessment against the employer for employer FICA
    taxes on such tips might also provide an incentive to an
    employer to discourage accurate reporting or to ignore clearly
    inaccurate reporting by its employees."); Morrison Restau-
    rants, 118 F.3d at 1530 ("[B]asing the employer's share of
    FICA taxes exclusively on employees' reported tips would
    provide incentive to the employer to discourage accurate

                                   2907
    reporting or ignore blatantly inaccurate reporting by the
    employees so that the employer could pay less FICA tax.").

    The IRS's interpretation--the one to which we owe
    deference--requires only that employers comply with the
    law; it is neither unfair nor a punishment. See Bubble Room
    II, 159 F.3d at 566 ("[W]e reject the position that the
    McQuatters formula [i.e., the aggregate method] is punitive in
    nature and thus limited to situations where taxpayers fail to
    keep adequate records."). Cf. Maj. Op. at 2887-88. Employers
    are required, by statute, to pay their share of FICA taxes on
    reported and unreported tips. Use of the aggregate method is
    not an effort to tell restaurants how to run their businesses. It
    is simply an alternate means of assessing the tax when indi-
    vidual employees' records are unavailable. Restaurants can
    continue to pool tips or not, to require certain reporting from
    their employees or not, and to create a specialized tip system
    or not. The choice lies with the restaurant, not the IRS. The
    consequence is that the tax is still owed and the IRS will
    impose a reasonable method to assess it. Because the IRS's
    conclusion that it can assess the employer's share of FICA
    taxes with respect to unreported tips based on the aggregate
    method is reasonable, we should defer to that interpretation,
    particularly here, in light of the need for uniformity in admin-
    istering the national tax system and the views of our sister cir-
    cuits.

    D. USE OF THE AGGREGATE METHOD DOES NOT PRECLUDE A
          CHALLENGE AS TO ACCURACY AND AMOUNT.

    The majority confuses the IRS's authority to use the aggre-
    gate method with the accuracy of that method. See Maj. Op.
    at 2884-85, 2888-89. "[W]hether there are flaws in the indi-
    rect formula used to estimate the FICA tax is a separate mat-
    ter from whether the IRS has the authority to assess an
    employer-only FICA tax based on an aggregate estimate of
    unreported tip income." Bubble Room II, 159 F.3d at 568.

                                   2908
    Adoption of the aggregate method does not preclude an
    employer from challenging the amount of the assessment by
    showing, for example, that some of the tips were received by
    employees who fell outside the wages band. See 330 West
    Hubbard Restaurant, 203 F.3d at 996 ("[The employer's]
    argument [regarding the wages band] is misplaced because it
    fails to distinguish between the IRS's authority to collect
    taxes and the correctness of the IRS's calculation of the
    amount of those taxes."); Bubble Room II, 159 F.3d at 567
    (concluding that failure to take the wages band into account
    does not "make the assessment unlawful" but, rather, "merely
    suggests that the amount of FICA tax assessed against [the
    employer] may have been incorrect by some margin and that
    it may be entitled to a refund of some portion of the FICA tax
    assessed against it"). Here, however, the issue of accuracy is
    not before us, because Fior d'Italia did not challenge the accu-
    racy of the calculation--it challenged only the IRS's authority
    to assess taxes under the aggregate method.

    The IRS is not just plucking a number out of the air and
    shifting the burden to the taxpayer as the majority would have
    us believe. Use of the aggregate method does not shift the
    normal burdens in some topsy-turvy manner. Instead, the
    aggregate method is predicated on a reasonable estimate and
    that may be challenged by the taxpayer. There is nothing new
    or unusual in this scheme of tax assessment.

    * * * * *

    Our review of the IRS's interpretation of the Code is lim-
    ited. Because the IRS's conclusion that it has the authority to
    use the aggregate method is reasonable, we must defer to it,
    as have three circuits before us. This approach preserves the
    right to challenge the accuracy of the assessment resulting
    from the aggregate method. Therefore, I respectfully dissent.

                                   2909

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