CANBY, Circuit Judge:
This appeal concerns a small mining company that, like others in its county, treated its workers as independent contractors for tax purposes. Two questions are before us. First, whether such treatment was justified under § 530(a)(2)(C) of the Revenue Act of 1978, 26 U.S.C. § 3401 note (1979), as undertaken in reliance on a "long-standing recognized practice of a significant segment of the industry." Second, for a later tax year to which...
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