Estate of Algerine Allen Smith, Deceased, James Allen Smith, Executor - Page 34

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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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