Binh met Anika 10 years ago at a cocktail party. Anika was a wealthy investor with extensive holdings in the oil and gas industry. Binh was a real estate agent earning about $35,000 a year. Several months later, Binh proposed marriage and Anika accepted. Just before the wedding, Anika told Binh that she had a ‘‘mental hangup’’ about marriage, and Binh agreed to live with her without being married. In return, Anika promised to leave Binh her entire estate. In the ensuing years, they had an intimate, marriage-like relationship, attending social, business, and family functions together. Anika died in 2008. No will was found immediately. A few months after Anika’s death, her sister found a one-page paper signed by Anika. The paper left Anika’s entire estate to her brothers and sisters and named her sister as executor of the estate. Binh sued Anika’s estate and won a judgment of $2 million for services rendered to Anika during their relationship. The estate appealed the decision, which was affirmed as to liability but reversed and remanded for a new trial on the amount of the judgment. Binh and the estate subsequently worked out an agreement in which the estate paid Binh $1.2 million to settle his claim.

Identify the tax issue(s) posed by the facts presented. Determine the possible tax consequences of each issue that you identify.