- 19 -
the convenience of the parties and judicial economy). We
disagree. First, we do not acquire jurisdiction from theories
based on public policy, convenience of the parties, or judicial
economy. See Trost v. Commissioner, 95 T.C. at 565; Judge v.
Commissioner, 88 T.C. at 1180-1181; Axe v. Commissioner, 58 T.C.
256, 259 (1972). Although petitioner contends that a broader
grant of jurisdiction might have provided an additional
efficiency regarding the resolution of worker classification
disputes, we believe section 7436 does not give us that
authority.
Second, section 7436 provides a reasonable and helpful
alternative to litigating worker classification cases in other
courts even if it does not provide jurisdiction to decide the
amounts of employment tax due. Before section 7436 was enacted,
the U.S. District Courts and Court of Federal Claims had refund
jurisdiction over employment classification, entitlement to
relief under section 530 of the Revenue Act of 1978, and other
employment tax issues. Congress found that disputes with the
Internal Revenue Service over worker classification and
entitlement to relief under section 530 of the Revenue Act of
1978 have been difficult for many taxpayers and decided to
provide for judicial review of these issues before this Court on
a prepayment basis. See sec. 7436(d); H. Rept. 105-148, supra;
S. Rept. 105-33, supra. Once these issues are decided, we
believe the parties will be much more likely to reach an
agreement about amounts of tax owing, if any. A Tax Court
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