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Despite Michael Jackson’s 2009 death, the late pop singer’s popularity has actually risen in California over recent years, increasing the overall value of the estate that he left behind. Although the estate has already proceeded through the estate administration process, the IRS claims that it is owed some hefty back taxes. The conflict boils down to the value of Jackson’s estate at the time of his death, a number that has eluded agreement.

Prior to his death, Jackson was planning to head out on a tour to mark his comeback onto the pop music scene. His earnings from licensing had dwindled based mostly on rumored drug use and allegations that he had inappropriate encounters with minors. Because of his complicated past, his estate put the value of Jackson’s likeness and name — not his entire estate — at a mere $2,105 at the time of his death.

The IRS disagrees, claiming Jackson’s name was worth at least $434 million, but some believe that the agency is basing that figure on posthumous earnings based on the singer’s name. A documentary featuring the pop star grossed over $260 million the same year of his death and sparked a resurgence in his popularity. That increased popularity did lead to increased earnings, which executors of the estate do not deny as they were able to pay off the remainder of Jackson’s debt. However, they dispute the IRS’ claim that his name and likeness was that valuable at the time of his death, noting that the resurgence in earning ability occurred only after he had already died.

So far this is a one-of-a-kind case in which the IRS and executors of an estate have such different views on an estate’s worth at the time of death. While discrepancies can and do occur, it is not normally on such a drastic level. Most people in California can avoid this type of estate administration dispute by ensuring that all necessary documents are kept current and in a safe and convenient location for executors.

Source: The Hollywood Reporter, “Michael Jackson Estate Faces Billion-Dollar Tax Court Battle“, Eriq Gardner, April 20, 2016