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economy and convenience to the parties, it was illogical for the
Tax Court to have jurisdiction over worker classification but not
over employment taxes assessed as a result of that
classification. Id. at 12. The Court held that “we do not
acquire jurisdiction from theories based on public policy,
convenience of the parties, or judicial economy”, and granted the
Commissioner’s motion to dismiss. Id. at 12-14.
In the present cases, petitioners argue that if the Court
has jurisdiction over many other aspects of petitioners’ tax
status, then for convenience to the parties and judicial economy,
the Court should also have jurisdiction over any penalties
assessed against petitioners. However, as noted above, we may
exercise our jurisdiction only to the extent authorized by
Congress. Moore v. Commissioner, 115 T.C. at 175; Naftel v.
Commissioner, 85 T.C. at 529. We do not acquire jurisdiction
from theories based on public policy. See Henry Randolph
Consulting v. Commissioner, supra at 12; see also Trost v.
Commissioner, 95 T.C. 560, 565 (1990). Therefore, petitioners’
public policy arguments are insufficient to allow this Court to
exercise jurisdiction over the section 6652(c)(1) penalties.
Conclusion
Petitioners have not pointed to any specific grant of
jurisdiction over section 6652(c)(1) penalties, and we can find
none. Instead, petitioners’ assertion that this Court has
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