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After Uncle Sam accused Whitney Houston’s estate of under reporting its federal taxes, her heirs have filed a petition to challenge what the IRS claims it owes.

According to Bloomberg’s reporting of the May 23rd petition, Houston’s estate objects 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 the Whitney Houston Estate also says the IRS has made a mistake by increasing the value of the singer’s publicity rights $11.5 million to $11.7 million.

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