Pop star Britney Spears is going to court over an IRS tax bill seeking more than $721,000 in additional taxes and penalties for the 2021 tax year. In a petition filed with the Tax Court on December 18, Spears seeks a redetermination of an IRS Notice of Deficiency dated September 22, 2025.

A taxpayer who receives a notice of deficiency generally has 90 days from the date the notice is mailed to file a petition with the Tax Court (150 days if the notice is addressed to a taxpayer outside the United States)—that’s why you’ll sometimes hear these notices referred to as 90-day letters. Filing a timely petition in Tax Court allows the taxpayer to litigate the dispute without first paying the tax, and typically prevents the IRS from assessing or collecting the deficiency while the case is pending.

According to the petition, the IRS claims Spears owes $600,719 in additional income tax and $120,143.80 in accuracy-related penalties under section 6662(a). The increase in tax is due to IRS adjustments of over $1.7 million, bringing her taxable income to just over $4.9 million. Spears disputes the full amount of the adjustment.

The most significant issue in the case is a $1.39 million adjustment the IRS made to Spears’ income based on her interest in Shiloh Standing Inc., an S corporation she owns. Because S corporations are pass-through entities, their income, deductions, and losses are reported by the shareholders on their individual returns. Here, the IRS disallowed certain business expenses claimed by Shiloh, increasing the corporation’s taxable income and, in turn, Spears’s personal tax liability.

Under section 162 of the tax code, a business expense is deductible only if it is........

© Forbes