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U.S. Tax Court: Valuation of performer’s image and likeness, music publishing trust and catalog

A memorandum opinion in a case concerning the valuation of an estate of a performance artist

A memorandum opinion in a case concerning valuation of an estate of performance artist

The U.S. Tax Court today issued a memorandum opinion in a case concerning the valuation of an estate of a performance artist.

The estate and the IRS agreed on the value of many assets, but continue to dispute the value of three intangible assets:

  • The decedent’s image and likeness
  • His interest in a music-publishing trust
  • His interest in a music-publishing catalog that owned the copyrights to compositions that the decedent wrote or cowrote, as well as compositions by other songwriters

In a 271-page opinion, the Tax Court summarized its findings with the following valuations (approximate values provided below):

Asset

Estate

IRS

Tax Court

Decedent’s image and likeness

$3.078 million

$161 million

$4.15 million

Music publishing trust

$0

$206 million

$0

Music catalog

$2.27 million

$114 million

$107 million


The case is: Estate of Jackson v. Commissioner, T.C. Memo 2021-48 (May 3, 2021). Read the Tax Court’s opinion [PDF 920 KB] (271 pages)

 

 

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