The pending tax court battle between Michael Jackson's estate and the IRS centers on the precise amount Jackson's name and likeness were worth at the exact moment of his death. Essentially, if Jackson could have sold his brand at the time, how much would he have been able to get?
Right now, years after his death, Jackson's name and image are extremely valuable. He has undergone a post death transformation. However, at the time of his death he was disgraced by accusations of child molestation.
The general, negative public opinion of Jackson at the time has led his estate to value the name and likeness at $2,105. The IRS on the other hand says they were worth $464 million.
The Hollywood Reporter says in "Michael Jackson Estate Faces Billion-Dollar Tax Court Battle" that if the IRS wins, interests and penalties could make the case worth $1 billion.
One of the interesting aspects of this particular case is that the IRS has never before asked that estate taxes be paid for a celebrity's name and likeness. That means it is unknown exactly where the IRS came up with the evaluation it did.
Jackson was preparing for an image rehabilitation tour at the time of his death and the IRS has sought information about corporate sponsorship of that tour. How sponsorship for one tour is extrapolated to $464 million name and likeness property value is unknown.
Needless to say, if the IRS wins this case, it will drastically change what other celebrities do with their estate plans.
Reference: Hollywood Reporter (April 20, 2016) "Michael Jackson Estate Faces Billion-Dollar Tax Court Battle