Britney Spears disputes flow-through income adjustment and accuracy penalty for 2021
Britney J. Spears v. Commissioner. United States Tax Court. No. 16456-25
Britney Spears is asking the Tax Court to throw out a $600,719 tax deficiency and a $120,144 accuracy-related penalty tied to S corporation income and itemized deductions on her 2021 return.
Key Facts
Petitioner: Britney Spears.
Year at issue: 2021.
Notice of Deficiency date: September 22, 2025.
Deficiency asserted: $600,719.
Accuracy-related penalty asserted: $120,143.80 under §6662(a).
Business entity: Shiloh Standing, Inc., an S corporation in the performing arts and entertainment.
Residence: California.
What the IRS Adjusted
Increased Spears’s pass-through income from Shiloh Standing, Inc. by $1,390,922.
Disallowed $334,372 of itemized deductions on Schedule A.
Imposed a §6662(a) accuracy-related penalty based on negligence, substantial understatement, and valuation overstatement theories.
Spears’s Position
The S corporation expenses were ordinary and necessary and can be substantiated.
Her reported share of income and expenses from Shiloh Standing, Inc. was correct.
The disallowed itemized deduc…
