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ent filed a response to the motion, in which he contends that the Court hasjurisdiction over all 16 quarters. - 18 - [*18] Discussion I. Section 7436 A. Overview Section 7436 was enacted as part ofthe Taxpayer ReliefAct of 1997, Pub. L. No. 105-34, sec. 1454(a), 111 Stat. at 1055, and it grants the Tax Court jurisdiction over cases involving employmenttaxes imposed under subtitle C. We explained in Am. Airlines, Inc. v. Commissioner, 144 T.C. 24, 32 (2015): As the Court has noted previously: "[I

1454(a), 111 Stat. at 1055, and grants the Court limitedjurisdiction over cases involving employmenttaxes imposed under subtitle C. Section 7436(a), as amended by the Consolidated Appropriations Act, 2001, Pub. L. No. 106-554, sec. 314(f), 114 Stat. at 2763A-643 (2000), provides: SEC. 7436(a). Creation ofRemedy.--If, in connection with an audi

1454(a), 111 Stat. at 1055, and grants the Court limitedjurisdiction over cases involving employmenttaxes imposed under subtitle C. Section 7436(a), as amended by the Consolidated Appropriations Act, 2001, Pub. L. No. 106-554, sec. 314(f), 114 Stat. at 2763A-643 (2000), provides: SEC. 7436(a). Creation ofRemedy.--If, in connection with an audi

1454(a), 111 Stat. at 1055, enacting section 7436 makes - 12 - abundantly clear that the April 15, 2011, letter was a determination. Section 7436 originated in the House ofRepresentatives. H.R. 2014, 105th Cong. (1997). In H.R. Rept. No. 105-148, at 639 (1997), 1997-4 C.B. (Vol. 1) 319, 961, the Explanation ofProvision states, in pertinentpar

employment taxes which relate to the Secretary’s determination concerning worker classification. Community Renewal Tax Relief Act of 2000 (CRTRA), Pub. L. 106- 554, sec. 314(f), (g), 114 Stat. 2763A-463; Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1454(a), 111 Stat. 1055. In light of Congress’s action, petitioner sought to amend the amended petition to place into dispute, as it had in its original petition, the amounts of employment taxes, additions to tax, and penalties determined by resp

Section 6665(a)(2) provides that, except as otherwise provided, any reference in Title 26 to a tax imposed by Title 26 shall be deemed also to refer to the additions to tax, additional - 10 - amounts, and penalties provided by chapter 68 of subtitle F.

tained, the correct liabilities can be recomputed under Rule 155. Discussion The parties dispute whether we have jurisdiction under section 74362 to decide the amounts of tax for which petitioner 2 Sec. 7436 was added to the Internal Revenue Code by sec. 1454(a) of the Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 788, 1055, effective Aug. 5, 1997. Before enactment of sec. 7436, the Tax Court lacked jurisdiction to decide worker classification disputes arising under subtitle C of the Co

09. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable periods in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7436 was added to the Internal Revenue Code by sec. 1454(a) of the Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 788, 1055, effective Aug. 5, 1997. Before enactment of sec. 7436, the Tax Court lacked jurisdiction to decide worker classification disputes arising under subtit. C of the Cod