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Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael Jackson’s, estate as shown in the United States Tax Court’s recent 271-page memorandum opinion.
See Estate of Jackson v. Comm’r, T.C. Memo. 2021-48.
Although the lengthy opinion boiled down to general valuation and estate tax principles, it was noteworthy for several reasons. First, the Tax Court explicitly found that the IRS’ expert had perjured himself during trial, resulting in a significant discounting of his offered opinions to the court. Second, the Tax Court was called upon to value significant intangible assets of Mr. Jackson at the time of his death, including his image and likeness. Third, the opinion offers additional insights into how estates, unlike individuals, bear the burden of sho
May 12, 2021 at 12:30 PM
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(Photo by Frazer Harrison/Getty Images)
Michael Jackson, the King of Pop, was for a time the most famous man in the world. Most of us remember him for his multiple hit songs during the ’80s and ’90s. Like some celebrities who have lives normal people can only dream of, he was not a chill, normal dude. He was known to be reclusive and had all sorts of eccentricities. Later in life, he again attracted media attention when he was the defendant in a civil lawsuit and a criminal trial where he was accused of child molestation. And finally, the world was shocked to learn about his untimely death under suspicious circumstances.
Michael Jackson photographed on Jan. 27, 1989.
The executors of the estate say the decision is a huge, unambiguous victory for Michael Jackson’s children.
More than four years after going head-to-head with the IRS in U.S. Tax Court, Michael Jackson s estate has emerged largely victorious with a federal judge finding the artist s worth at the time of his death to be much closer to its estimate than the government s and declining to issue any penalties.
The dispute centered on how much Jackson s image and likeness were worth when he died in 2009, which would determine how much in taxes the estate would owe the IRS. It also includes the worth of Jackson s interest in New Horizon Trust II, which included his stake in Sony/ATV Music Publishing, and New Horizon Trust III, which included Mijac Music, a publishing catalog that owned the copyrights to compositions Jackson wrote or co-wrote and works by other songwriters. (The estate and IRS generally agreed on the value of the othe
Michael Jackson’s Likeness Valued at $4.1 Million in Big Tax Court Win for Estate
Steve Granitz/WireImage
The executors of the estate say the decision is a huge, unambiguous victory for Michael Jackson’s children.
More than four years after going head-to-head with the IRS in U.S. Tax Court, Michael Jackson s estate has emerged largely victorious with a federal judge finding the artist s worth at the time of his death to be much closer to its estimate than the government s and declining to issue any penalties.
The dispute centered on how much Jackson s image and likeness were worth when he died in 2009, which would determine how much in taxes the estate would owe the IRS. It also includes the worth of Jackson s interest in New Horizon Trust II, which included his stake in Sony/ATV Music Publishing, and New Horizon Trust III, which included Mijac Music, a publishing catalog that owned the copyrights to compositions Jackson wrote or co-wrote and works by other songwriters. (