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          liabilities, we stated how the principles of each section listed            
          in section 7436(d) could apply to a section 7436, before                    
          amendment by CRTRA, case even if we lacked jurisdiction to decide           
          the amounts of tax due.  With regard to the possible application            
          of the principles of section 6214(a) to section 7436, before                
          amendment by CRTRA, we stated that the interaction of those two             
          sections may allow us to “decide worker classification claims               
          raised by the Commissioner that are not included in the notice of           
          determination (e.g., a claim regarding the status of additional             
          persons alleged to be employees) if such claims relate to the               
          taxpayer and taxable periods in the notice of determination.”               
          Id. at 6.                                                                   
               It is well established that the Court has jurisdiction to              
          review an increased deficiency asserted by the Commissioner at or           
          before the hearing or rehearing.  Sec. 6214(a); Ferrill v.                  
          Commissioner, 684 F.2d 261, 265 (3d Cir. 1982), affg. T.C. Memo.            
          1979-501; H.F. Campbell Co. v. Commissioner, 443 F.2d 965, 970              
          (6th Cir. 1971), affg. 53 T.C. 439 (1969); Commissioner v.                  
          Finley, 265 F.2d 885, 888 (10th Cir. 1959), affg. O’Shea v.                 
          Commissioner, T.C. Memo. 1957-15 and T.C. Memo. 1957-16;                    
          Henningsen v. Commissioner, 243 F.2d 954, 959 (4th Cir. 1957),              
          affg. 26 T.C. 528 (1956).                                                   
               We conclude that, pursuant to section 7436, we have                    
          jurisdiction over the Commissioner’s affirmative allegations                






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