Ah, you're right. It's a list but not a cons.
$ sbcl
* (symbolp nil)
T
* (listp nil)
T
* (consp nil)
NIL
Is there a boolean predicate? My Common Lisp is rusty and I don't see one at https://www.cs.cmu.edu/Groups/AI/html/cltl/clm/node73.html#S....