Service Employees International Union - Page 14

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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.                
               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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