Special guest Whitney Houston at  the Songwriters Hall of Fame 32nd Annual Awards at The Sheraton New York Hotel and Towers in New York City on June 14, 2001 Photo by Scott Gries/ImageDirect

Whitney Houston at the Songwriters Hall of Fame 32nd Annual Awards at The Sheraton New York Hotel and Towers in New York City on June 14, 2001

*After Uncle Sam accused Whitney Houston’s estate of underreporting 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.

How the IRS came to its valuation is unclear, but this provides further evidence that the federal tax agency intends to pursue money from the name and image of dead stars, notes The Hollywood Reporter’s Eriq Gardner:

With a trial scheduled for next February, the IRS is currently in court with the Michael Jackson Estate over the value of the King of Pop’s publicity rights. There, the IRS once asserted the value of these rights upon death was $434 million — it’s recently backed off from this precise amount — while the Michael Jackson Estate argued just $2,105.