Estate of Shapiro v. United States

634 F.3d 1055 (2011)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Estate of Shapiro v. United States

United States Court of Appeals for the Ninth Circuit
634 F.3d 1055 (2011)

Facts

Cora Chenchark lived with Bernard Shapiro for 22 years in a romantic, unmarried relationship. While the two were together, Chenchark provided homemaking services to Shapiro, such as cooking, cleaning, and generally managing their household matters. When the couple broke up, Chenchark sued Shapiro for palimony payments. Chenchark claimed that Shapiro had promised her that she would be taken care of even if something happened to him. Shapiro died while the lawsuit was pending. Shapiro’s estate (plaintiff) ultimately settled Chenchark’s claim for $1 million and deducted the claim as an expense. The federal government (defendant) determined that Chenchark’s claim was not based on a bona fide contract in which Chenchark had provided consideration in the form of money or something like money and, therefore, that Chenchark’s claim was not a deductible expense. The estate filed a lawsuit in federal district court claiming that Chenchark’s claim was a deductible expense under 26 U.S.C. § 2053(c)(1)(A) and seeking a tax refund based on the deduction. The district court granted summary judgment to the federal government. The court based its ruling on evidence that Chenchark had provided only herself, her love, and her affection to Shapiro, none of which increased Shapiro’s gross estate. Therefore, the district court ruled that Chenchark had not provided consideration in money or money’s worth to Shapiro and that Shapiro’s estate’s payment to Chenchark was a nondeductible gift to a romantic partner—not a deductible claim under a bona fide contract for monetary consideration. The estate appealed.

Rule of Law

Issue

Holding and Reasoning (Silverman, J.)

Dissent (Tashima, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership