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Beyonce Knowles-Carter takes on the nation’s most powerful debt collection agency, the Internal Revenue Service.

According ForbesBeyonce has filed a petition in US Tax Court challenging nearly $2.7 million in taxes and penalties levied by the IRS.

The April 23 motion asks the court to reconsider additional tax and penalties on unpaid or overdue debts in a Notice of Deficiency dated January 18, 2023.

The penalties imposed by the IRS are 20% of the amount of debt owed by the taxpayer.

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Beyonce disputes the breach, saying the IRS disallowed millions of dollars in tax deductions and write-offs, including $868,766 in charitable contributions.

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Beyonce argued in her motion that the penalties should not apply because she “acted reasonably and in good faith” to pay off her tax debt.

Bey filed the petition with the Tax Court as the sole taxpayer. Jay Z was not included in the petition, according to Forbes.

Jay Z claims to be hip-hop’s first billionaire, with an estimated net worth of $2.5 billion.