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Smith v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit
113 F.2d 114, 25 A.F.T.R. (P-H) 344, 1940 U.S. App. LEXIS 3319 (1940)
ELI5:

Rule of Law:

The court did not articulate a rule of law, as the opinion consists of a single-sentence per curiam order affirming the lower court's decision without providing any legal reasoning or analysis.


Facts:

  • The underlying facts of the dispute between Henry C. and Lillie M. Wright Smith and the Commissioner of Internal Revenue are not provided in the court's opinion.

Procedural Posture:

  • Henry C. and Lillie M. Wright Smith (Petitioners) were parties to a proceeding against the Commissioner of Internal Revenue (Respondent) before a lower tribunal, likely the U.S. Board of Tax Appeals.
  • The lower tribunal ruled in favor of the Commissioner of Internal Revenue.
  • The Smiths, as petitioners, sought review of the adverse decision from the United States Circuit Court of Appeals for the Second Circuit.

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Issue:

The specific legal issue is not stated in the court's per curiam opinion.


Opinions:

Per curiam - Per Curiam

The court affirmed the decision of the lower court without providing any legal reasoning or analysis. The entirety of the court's opinion is the statement, 'Decision affirmed.'



Analysis:

This per curiam affirmance holds no precedential value because it lacks any statement of facts, legal issue, or reasoning. It serves only to terminate the litigation for the specific parties involved. Such summary affirmances are typically issued when an appellate court entirely agrees with the lower court's decision and reasoning, believing no further judicial explanation is necessary.

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