- 6 -
(2000); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). This
Court generally has deficiency jurisdiction over income, gift,
and estate tax cases. See secs. 6211(a), 6213(a), 6214(a);
Downing v. Commissioner, 118 T.C. 22, 27 (2002); Van Es v.
Commissioner, 115 T.C. 324, 328 (2000). For purposes of section
6330(d), this Court may have jurisdiction over an underlying
liability for income, estate, or gift tax even when no deficiency
has been determined. Montgomery v. Commissioner, 122 T.C. 1, 7-8
(2004); Downing v. Commissioner, supra at 27-28; Landry v.
Commissioner, 116 T.C. 60, 62 (2001). However, the Court’s
jurisdiction over collection matters under section 6330(d)(1) is
limited to the types of tax over which it normally has
jurisdiction. See Van Es v. Commissioner, supra at 328-329;
Moore v. Commissioner, supra at 175.
Section 7436(a) confers jurisdiction over employment tax
liabilities on this Court, but the Court’s jurisdiction is
limited to controversies involving a worker’s employment status.7
See Charlotte’s Office Boutique v. Commissioner, 121 T.C. 89,
102-103 (2003), supplemented by T.C. Memo. 2004-43, affd. 425
F.3d 1203 (9th Cir. 2005); Ewens & Miller, Inc. v. Commissioner,
117 T.C. 263, 267 (2001). Respondent argues that this Court
lacks jurisdiction over Mr. Salazar’s employment tax liabilities
7Sec. 7436(a) was amended by the Consolidated Appropriations
Act of 2001, Pub. L. 106-554, sec. 314(f), 114 Stat. 2763A-643,
to confer such jurisdiction.
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