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also United States v. Beggerly, supra at 45-46, and a court has
jurisdiction over that proceeding if it had jurisdiction over the
original suit, Smith v. Widman Trucking & Excavating, Inc., 627
F.2d 792, 799 (7th Cir. 1980); see also Charter Township v. City
of Muskegon, 303 F.3d 755, 760-763 (6th Cir. 2002).
B. This Court’s Predecessors
The roots of this Court, the United States Tax Court, are
traced to the Revenue Act of 1924, ch. 234, sec. 900(a), (k),
43 Stat. 336, 338, wherein Congress established the Board of Tax
Appeals (Board) as “an independent agency in the executive branch
of the Government.” In the Revenue Act of 1942, ch. 619, sec.
504, 56 Stat. 798, 957, Congress changed the name of the Board to
the “Tax Court of the United States” but did not change the
latter tribunal’s designation as an independent agency within the
Executive Branch. That designation was changed in the Tax Reform
Act of 1969 (1969 Act), Pub. L. 91-172, sec. 951, 83 Stat. 487,
730. There, through its enactment of section 7441, Congress
“hereby established, under article I of the Constitution of the
United States, a court of record to be known as the United States
Tax Court.”
The predecessors to this Court were not courts of law, and
they did not possess the judicial powers of a District Court. As
independent agencies in the Executive Branch, this Court’s
predecessors had only those powers which were conferred upon them
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