How Will I Know? IRS Claims Whitney Houston's Estate Undervalued Her Right Of Publicity By $11.5 Million

Following up on my previous posts (links below) on the IRS's battle with the estate of Michael Jackson over the value of the singer's publicity rights:  Hollywood Reporter, Whitney Houston Estate Challenges $11 Million Tax Bill:

The heirs of late pop star Whitney Houston are now in Tax Court over what the Internal Revenue Service claims is owed in estate taxes.

In a May 23 petition, now sealed and first reported by Bloomberg, the Whitney Houston estate objected to the determination that $22.6 million has been underreported, which the IRS claims means that more than $11 million is owed, including $3 million in penalties.

Some of the money is attributable to song and performance royalties, including a $9 million dispute over the worth of catalog albums, but it's another discrepancy that is particularly eye-opening.

The Whitney Houston estate said the IRS is in error by increasing the value of the singer's publicity rights from $11.5 million to $11.7 million. How the IRS came to its valuation is unclear, but this provides further evidence that the federal tax agency intends to pursue money from the name and image of dead stars.

Prior TaxProf Blog Posts:

• Michael Jackson's Looming "Estate Tax Disaster" (June 29, 2009)
• What Is Michael Jackson's Name Worth? Estate Says $2,105, IRS Says $434,000,000 (Nov. 12, 2013)
• Robin Williams Left Publicity Rights (Restricted For 25 Years) to Charity, Avoiding IRS Dispute Embroiling Michael Jackson's Estate (Mar. 31, 2015)
• Michael Jackson's $1 Billion Tax Court Thriller: IRS Values His Name At $434,000,000, Estate Says $2,105 (Apr. 25, 2016)