The United States Tax Court is a Court of Record
IT IS NOT AN ADMINISTRATIVE COURT
Tax Court is a court of record. It is not an administrative court unless you permit it to quit being a court of record. (nisi prius)
Here is what the Internal Revenue Code designates:
26 U.S.C. 7441: Status. "There is 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 members of the Tax Court shall be the chief judge and the judges of the Tax Court."
(Aug. 16, 1954, ch. 736, 68A Stat. 879; Pub. L. 91–172, title IX, § 951, Dec. 30, 1969, 83 Stat. 730; Pub. L. 114–113, div. Q, title IV, § 441, Dec. 18, 2015, 129 Stat. 3126.)
All federal courts are courts of record; not just the United States Tax Court.
US. Code, TITLE 28 > PART I > CHAPTER 5 > § 132. Creation and composition of district courts.
(a) There shall be in each judicial district a district court which shall be a court of record known as the United States District Court for the district.
U.S. Code, TITLE 26 > Subtitle F > CHAPTER 76 > Subchapter C > PART I > § 7441. Status.
There is 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 members of the Tax Court shall be the chief judge and the judges of the Tax Court.
(a) There shall be in each judicial district a district court which shall be a court of record known as the United States District Court for the district.
U.S. Code, TITLE 26 > Subtitle F > CHAPTER 76 > Subchapter C > PART I > § 7441. Status.
There is 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 members of the Tax Court shall be the chief judge and the judges of the Tax Court.