Estate of Shapiro, et al. v. United States, 634 F.3d 1055 (9th Cir. 2011)

(palimony case involving claim for federal estate tax deduction; couple lived together (never married) for 22 years before splitting up; she files for palimony under implied contract that couple agreed to pool assets; before trial, he died and trial court ultimately determined no such implied contract existed; his estate paid estate tax exceeding $10 million and filed refund claim for about $5 million on basis that estate was worth less due to palimony suit; trial court awards government summary judgment on basis that what she gave (love and support) was inadequate consideration to support enforceable contract and that there was no contract to begin with, and that estate was estopped on basis that estate claimed at trial that there was no enforceable contract; reversed on appeal - her love and support were valid consideration under state (Nevada) law and issues of genuine fact remained about value of her claim; thus, estate may be entitled to refund; dissent claims that state law immaterial - I.R.C. provides no deductions for palimony claims based solely on love and support).