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the Tax Court from the Executive Branch and established
it as an article I court primarily for the purpose of
recognizing its status as a judicial body and disposing
of any problems that its status as an executive agency
sitting in judgment on another executive agency might pose.
This Court's District Courtlike status means that the Court's
decisions are subject to review only by a Federal appellate
court. See sec. 7482(a) ("The United States Courts of Appeals
* * * shall have exclusive jurisdiction to review the decisions
of the Tax Court * * * in the same manner and to the same extent
as decisions of the district courts in civil actions tried
without a jury").
Appellate courts have repeatedly applied the law that
preceded the 1969 Act to hold that the predecessors of the United
States Tax Court were not courts of law and, more importantly,
that these predecessors lacked judicial powers. In Lasky v.
Commissioner, 235 F.2d 97 (9th Cir. 1956), affd. per curiam
352 U.S. 1027 (1957), for example, the Court of Appeals for the
Ninth Circuit held that the Tax Court of the United States,
unlike a District Court, was without authority to vacate a final
decision. The Ninth Circuit reasoned that the Tax Court of the
United States was "not a court at all but merely an
administrative agency". Id. at 98; accord Swall v. Commissioner,
122 F.2d 324 (1st Cir. 1941); Sweet v. Commissioner, 120 F.2d 77
(1st Cir. 1941). Other appellate courts had ruled similarly,
applying the same reasoning. See, e.g., White's Will v.
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