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“independent agency in the Executive Branch” to a “court of
record” “established * * * under Article I of the Constitution”.
See sec. 7441 before and after amendment by the 1969 Act; see
also Freytag v. Commissioner, supra at 890-891. This Court
currently sits as a district courtlike tribunal that “exercises a
portion of the judicial power of the United States * * * to the
exclusion of any other function”. Id. at 891. This Court’s
district courtlike status means that its decisions are subject to
review only by a Federal appellate court. See sec. 7482(a).
E. Freytag v. Commissioner
In Old Colony Trust Co. v. Commissioner, 279 U.S. at 725,
the Supreme Court held that the Board was not a court but was
merely an executive or administrative board. The Supreme Court
also held that proceedings in the Board were administrative
inquiries and not judicial proceedings. Id. In Freytag v.
Commissioner, supra at 885, respondent argued that the 1969 Act
did not change these features as to this Court. The Supreme
Court disagreed. In contrast to its earlier decision as to the
status of the Board, the Supreme Court held that Congress through
the 1969 Act had established this Court as a court of law that
functions much like a District Court in this Court’s exclusive
exercise of a portion of the judicial power of the United States.
Id. at 890-892. The Supreme Court noted that this Court is
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