§7105

Commissioner, 755 F.3d at 943-944, made no constitutional distinction between the Tax Court and independent executive branch agencies even though, unlike the Tax Court, independent executive branch agencies exercise executive power under 3°The Court ofAppeals in Kuretski v. Commissioner, 755 F.3d at 944, cited several examples ofindependent agencies which "sit in 'independent' judgment of other executive actors." For instance, the Merit Systems Protection Board sits in judgment ofother agencies,