Estate of Shapiro v. United States

I agree with the majority’s disposition of the Us pendens and administrative expenses issues. I therefore concur in Parts II.D and II.E of the majority opinion. See Maj. Op. at 1060-61. I disagree, however, with the majority’s analysis and disposition of the primary issue in this appeal, the valuation of the Chenehark claim for federal estate tax purposes. I therefore respectfully dissent from Part II.B of the majority opinion.1 See Maj. Op. at 1057-60.

The majority reverses the district court because its holding “was premised upon a misconstruction of Nevada law regarding contracts between…