On May 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Jackson v. Commissioner (T.C. Memo. 2021-48). Two primary issues were dealt with in this gargantuan (271 pages) opinion by Judge Holmes. The primary issue in Estate of Jackson v. Commissioner was the valuation of three contested assets, Michael Jackson’s image and likeness, and the estate’s interest in two trusts through which the estate held an interest in Sony/ATV