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          The reports do not state that section 7436(c) and (d) provide                
          procedural rules, but it appears that those are the procedural               
          rules referred to in this legislative history.                               
               Petitioner contends that the legislative history for section            
          7436 shows that we have jurisdiction to decide the amounts of                
          employment tax due for the workers whose status is before the                
          Court.  We disagree.  The legislative history states that                    
          Congress intended that we decide "certain"8 and not all employment           
          tax disputes, and does not state that we should decide any issues            
          other than those specified in section 7436(a).                               
          C.   Section 7436 Compared to Declaratory Judgment Provisions                
               Petitioner points out that section 7436 differs in several              
          ways from the declaratory judgment provisions (sections 7428,                
          7476, 7477, 7478, 7479), and contends that this shows that                   
          Congress intended to provide jurisdiction to decide the amounts              
          of employment tax due.  Petitioner points out that section 7436              
          and the declaratory judgment provisions differ in that (1)                   
          section 7436(a) uses the term "determination", and the                       
          declaratory judgment provisions state "make a declaration"; (2)              
          section 7436 incorporates the principles of several sections that            
          pertain to deficiency procedures, and the declaratory judgment               

               8 The House and Senate committee reports stated as reasons              
          for change:                                                                  
                         It will be advantageous to taxpayers to                       
                    have the option of going to the Tax Court to                       
                    resolve certain disputes regarding employment                      
                    status.  [H. Rept. 105-148, at 639 (1997); S.                      
                    Rept. 105-33, at 304 (1997); emphasis added.]                      

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