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jurisdiction under section 7436 to decide the amounts of
employment tax due. Thus, we conclude that section 7436(c) does
not provide, or imply that we have, jurisdiction to decide the
amount of employment tax due in a case arising under section
7436.
4. Conclusion Based on the Text of Section 7436
Petitioner contends that if we read section 7436(a), (c),
and (d) together, section 7436 provides jurisdiction to decide
amounts of employment tax liability. We disagree. We see no
difference in the meaning of section 7436 whether each subsection
is analyzed separately or the entire section is analyzed as a
whole. Based on the text of section 7436(a), (c), and (d) we
conclude that we lack jurisdiction to decide the amounts of tax
due in cases arising under section 7436.
B. Legislative History
Petitioner contends that the legislative history of section
7436 shows that Congress intended for us to have jurisdiction to
decide amounts of employment tax liability. We disagree.
Nothing in the legislative history conflicts with our
construction of section 7436. The House and Senate committee
reports accompanying enactment of section 7436 use the same terms
to describe our jurisdiction as appear in section 7436(a). Both
reports said that Congress intended to create jurisdiction for us
to decide certain employment status disputes, and neither report
states that we have jurisdiction to decide amounts in dispute.
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