Why Most Date-of-Death Appraisals Quietly Fail IRS Review in 2026 — And How to Avoid It in Atlanta, Georgia
Many estates don’t fail because of value.
They fail because the report doesn’t meet IRS “qualified appraisal” standards — even when prepared by a licensed real estate appraiser.
Step 1 — The IRS Does Not Accept “Any” Appraisal
Most consumers assume:
“If it’s a licensed appraiser, the IRS will accept it.”
Not necessarily.
For federal estate tax (Form 706), gift tax (Form 709), or charitable contribution deductions, the IRS requires a qualified appraisal prepared by a qualified appraiser under Treasury Regulations §1.170A-17 and §20.2031-1.
That raises immediate questions:
• What makes an appraisal “qualified”?
• What makes an appraiser “qualified” for IRS purposes?
• Does a state license automatically satisfy IRS standards?
The answer is more nuanced than most expect.
Step 2 — “Qualified Appraiser” Is a Federal Standard — Not Just a State License
Searching “IRS qualified appraiser near me” in Atlanta will return hundreds of licensed appraisers.
But the IRS standard requires:
• Verifiable appraisal education
• Regular appraisal practice
• No prohibited fee arrangements
• No conflict of interest
• Proper documentation in the report
A licensed appraiser who primarily does lender work may not automatically structure reports to withstand federal tax scrutiny.
That’s where many date-of-death appraisals fail quietly — not in value, but in documentation.
Step 3 — Date-of-Death Appraisals Must Anchor to the Exact Valuation Date
A DOD appraisal must reflect:
The fair market value of the property on the decedent’s date of death — not the inspection date.
This means:
• Time adjustments must be credible and supported
• Comparable sales must bracket the valuation date
• Market condition commentary must address historical trends
• Data must be retained for potential IRS audit review
If the report reads like a standard “current market value” appraisal, it can raise red flags.
Step 4 — Restricted Appraisal Reports Are Often the Weak Link
One of the most common inquiries:
“Will the IRS accept a restricted appraisal report?”
In many estate or gift tax situations, a restricted-use report may not contain sufficient detail to meet qualified appraisal requirements.
Restricted reports are designed for limited users and limited intended use.
The IRS is not a limited intended user.
If the documentation is insufficient, the deduction or reported value can be challenged — even if the value itself is reasonable.
Step 5 — Form 706 and 709 Have Specific Documentation Expectations
For estate tax (Form 706), the appraisal must:
• Clearly identify the property
• State the effective valuation date
• Define the interest being appraised (fee simple, fractional, etc.)
• Include methodology explanation
• Contain a signed certification meeting IRS standards
Gift tax (Form 709) has similar documentation expectations.
Missing any of these components can create risk — not immediately, but years later during review.
Step 6 — Charitable Contribution Appraisals Have Their Own Standards
If the property is being donated and a deduction claimed:
The appraisal must comply with IRS “qualified appraisal” rules for charitable contributions.
Again, not every appraisal format satisfies this.
And not every appraiser structures reports with audit defense in mind.
So let’s answer the questions clearly.
Will the IRS accept a restricted appraisal report?
Often no — not for federal estate or gift tax filings that require full qualified appraisal documentation.
What are the IRS guidelines for a date-of-death appraisal?
It must reflect fair market value on the exact date of death, include full methodology explanation, and be prepared by a qualified appraiser under federal standards.
Does searching “IRS qualified appraiser near me” guarantee compliance?
No. State licensing and IRS qualification standards overlap — but they are not identical.
What about Form 706 appraisal requirements in Georgia?
The federal standards apply nationwide, including Atlanta, Fulton, Cobb, Gwinnett, and DeKalb counties. Local market data must support the historical valuation date.
Here’s the bottom line:
Most estate valuation problems don’t happen because of overvaluation or undervaluation.
They happen because the appraisal wasn’t structured for IRS scrutiny from the beginning.
If you are filing Form 706, reporting a taxable gift, or claiming a charitable deduction in 2026, the structure of the report matters just as much as the number.
At REI Valuations & Advisory, we structure date-of-death and federal tax appraisals specifically for IRS reporting — with documentation designed to withstand review.
If you contact us before filing:
• We will confirm whether a restricted or full report is appropriate
• We will identify risk gaps before submission
• We will provide a compliance checklist you can share with your CPA or attorney
• We will reserve audit-support documentation in our workfile
Due to workload limits and valuation date research requirements, we only accept a limited number of IRS-structured assignments each month.
If you need a qualified appraisal for estate, gift tax, or charitable reporting in Atlanta, schedule your Appraisal Fit Call before filing deadlines approach.
Because once a return is filed, correcting valuation documentation becomes significantly more complicated.
February 16th 2026 7:01pm
IRS Qualified Appraisal Requirements in 2026-Date of Death, Gift Tax & Estate Valuation Rules When a Restricted Appraisal May Be Rejected in Atlanta, Georgia
Whether you are filing Form 706, reporting a gift, substantiating a charitable deduction, or documenting a date of death valuation in Atlanta, Georgia, the IRS does not accept incomplete or unsupported appraisals. Here’s what qualified appraisal compliance actually requires in 2026.
The IRS Requires a “Qualified Appraisal” — Not Just an Appraisal
For estate tax (Form 706), gift tax (Form 709), charitable contributions, and other federal reporting, the IRS requires a qualified appraisal prepared by a qualified appraiser.
This is a legal standard — not a marketing term.
If the report does not meet regulatory requirements, it may be disregarded.
Date of Death Valuations Must Be Anchored to the Exact Effective Date
The IRS expects:
• Comparable sales near the effective date
• Time adjustments if necessary
• Market condition analysis
• Clear identification of valuation date
A refinance-style appraisal dated months later is not sufficient for compliance.
Estate Tax (Form 706) Appraisal Requirements
For federal estate tax reporting:
• Fair market value must reflect §20.2031-1 standards
• The appraiser must disclose qualifications
• The report must explain methodology
• The valuation must be defensible under examination
Insufficient documentation increases audit vulnerability for the executor and advisory team.
Gift Tax Appraisal Requirements (Form 709 Context)
For taxable gifts involving real estate:
• The valuation must reflect fair market value on the date of transfer
• Discounts (if applicable) must be explained
• Market support must be documented
• The appraisal must stand independently
Undervaluation may trigger penalties if challenged.
Charitable Contribution Appraisal Standards
For substantial non-cash real estate contributions:
• A qualified appraisal is required
• The report must contain required declarations
• The appraiser must meet independence standards
• Summary statements may be required for filing
Failure to meet technical requirements can result in deduction disallowance.
A Restricted Appraisal Is Not Automatically Rejected — But It Is Often Inadequate
Under USPAP, restricted-use reports may be permitted for certain client scenarios.
However, for IRS reporting, the issue is whether the report includes:
• Full scope explanation
• Market data transparency
• Valuation methodology
• Certification language
• Intended use disclosure
• Independence affirmation
Many low-cost restricted reports omit critical components required for IRS compliance.
The IRS Reviews Substance Over Label
Calling a report “restricted” does not cause rejection.
Lack of documentation does.
The IRS evaluates whether the report provides enough information to understand how value was determined and whether it meets regulatory standards.
Liability Exposure for Executors, CPAs & Attorneys
Executors have fiduciary duties.
CPAs must exercise due diligence.
Estate attorneys must ensure defensible documentation.
An insufficient appraisal can expose the entire advisory team to risk if valuation is adjusted upon review.
What does the IRS actually require in 2026?
For date of death valuations, estate tax filings, gift tax reporting, and charitable contributions, the IRS requires a qualified appraisal prepared by a qualified appraiser that fully substantiates fair market value as of the correct effective date.
A restricted appraisal report is not automatically rejected.
But if it lacks sufficient detail, analysis, independence, or compliance language, it may fail to qualify — regardless of cost or convenience.
For estates and tax matters in Atlanta, Fulton, Cobb, Gwinnett, and DeKalb Counties, valuation reports must be structured specifically for federal reporting purposes — not repurposed from lending or informal assignments.
In IRS matters, documentation depth equals protection.
• Date of Death
• Form 706 estate tax
• Gift tax reporting
• Charitable contribution substantiation
Contact REI Valuations & Advisory before filing.
Call 404-692-3878
Email reivaluations@gmail.com
Bonus: We offer a complimentary pre-engagement compliance review call to confirm whether your current appraisal structure meets IRS qualified appraisal requirements before submission.
Once filed, deficiencies become far more difficult to correct.
Protect the valuation before it is submitted.
Frequently Asked Questions About IRS Qualified Appraisals in Atlanta, Georgia
What are the IRS requirements for a qualified appraisal in 2026?
A qualified appraisal must be prepared by a qualified appraiser and include a clear valuation methodology, the correct effective date, sufficient comparable market data, scope of work disclosure, and required certification language. The report must provide enough detail for the IRS to understand how fair market value was determined for estate, gift, or charitable reporting purposes.
Will the IRS accept a restricted appraisal report for Form 706 or estate tax filings?
The IRS may accept a restricted appraisal report only if it meets all qualified appraisal requirements and fully substantiates fair market value as of the date of death. If the report lacks sufficient documentation, analysis, or compliance elements required under federal regulations, it may be rejected regardless of its label.
What does the IRS require for a date of death real estate appraisal?
For estate tax and step-up in basis reporting, the appraisal must determine fair market value as of the exact date of death. The report should include comparable sales near that date, time adjustments when necessary, and a clear explanation of market conditions and valuation methodology.
Are appraisal requirements different for gift tax reporting?
Yes. For gift tax reporting, fair market value must be determined as of the date of transfer. The appraisal must document market support, explain valuation methodology, and be defensible if reviewed. Undervaluation may result in penalties if challenged by the IRS.
Do charitable contribution real estate donations require a qualified appraisal?
Yes. Significant non-cash real estate charitable contributions require a qualified appraisal prepared by a qualified appraiser. The report must meet federal documentation standards and include required declarations to properly support the deduction.
Who is considered a qualified appraiser under IRS rules?
A qualified appraiser is an individual who meets education and experience requirements, regularly performs appraisals for compensation, demonstrates competency in valuing the specific type of property, and maintains independence from the transaction being reported.
February 15th 2026 4:26pm
IRS Qualified Appraiser Near Me in Atlanta (2026): Will the IRS Accept Your Date of Death Appraisal — or Reject It?
If you are filing Form 706, reporting a gift tax transfer, or documenting a charitable contribution in Atlanta, Georgia, the IRS does not accept informal valuations, CMAs, or restricted reports. Here is what qualifies in 2026 — and what could expose your estate filing to audit risk.
When someone searches “IRS qualified appraiser near me,” they are not price shopping.
They are protecting a federal tax filing.
A rejected valuation can delay an estate closing, trigger additional documentation requests, or invite scrutiny that could have been avoided with a properly prepared qualified appraisal.
The real question is not whether you need an appraisal.
The real question is whether the IRS will accept the one you submit.
Step 1 — Understand What the IRS Actually Requires
Under Treasury Regulation §1.170A-13(c) and Internal Revenue Code §2031, a qualified appraisal must:
• Be prepared by a qualified appraiser
• Include a clear effective date of value (date of death or transfer)
• Describe the property in sufficient detail
• Explain the valuation methodology used
• Analyze comparable market data
• Include a signed appraiser declaration
If any of these elements are missing, the report may fail federal compliance standards.
Step 2 — Know When a Qualified Appraisal Is Mandatory
A qualified appraisal is typically required for:
• Form 706 Estate Tax Returns
• Gift Tax Reporting
• Charitable Real Estate Contributions
• Step-Up in Basis Documentation
• Certain state tax reporting requirements
Automated estimates, broker price opinions, and informal opinions of value do not satisfy federal documentation standards.
Step 3 — Date of Death Appraisals Carry Special Risk
A Date of Death appraisal is retrospective.
That means the valuation must reflect fair market value as of the effective date — not today’s market.
It requires:
• Market condition analysis as of the date of death
• Comparable sales within reasonable proximity to the effective date
• Proper reconciliation under USPAP
• Alignment with the IRS definition of fair market value
Errors in retrospective methodology are one of the most common weaknesses in estate filings.
Step 4 — Will the IRS Accept a Restricted Appraisal Report?
In most federal filing scenarios involving estate tax, gift tax, or charitable contributions, a restricted report is insufficient.
Restricted reports are typically designed for limited users and may omit disclosures required under federal tax standards.
For Form 706 and related filings, the appraisal must meet full qualified appraisal documentation requirements.
Step 5 — What “IRS Qualified Appraiser” Actually Means
• Have verifiable education and experience
• Regularly perform appraisals for compensation
• Demonstrate familiarity with federal valuation requirements
• Be independent from the taxpayer
• Sign the appropriate declaration
Not every probate appraiser automatically qualifies under federal tax reporting standards.
“IRS qualified appraiser near me”
“Form 706 appraisal requirements”
“Qualified appraisal requirements”
“IRS guidelines for date of death appraisal PDF”
“Will the IRS accept a restricted appraisal report?”
Here is the direct answer:
The IRS requires a qualified appraisal prepared by an independent, experienced appraiser that complies with federal documentation standards and supports fair market value as of the correct effective date.
CMAs, automated values, and restricted-use reports generally do not meet those standards for estate tax, gift tax, or charitable contribution filings.
For Date of Death appraisals in Atlanta, Georgia (2026), the valuation must align with both USPAP and applicable federal tax regulations to withstand scrutiny.
If you are facing a Form 706 deadline or need a defensible Date of Death appraisal in the Atlanta metropolitan area (Fulton, Cobb, Gwinnett, DeKalb, Douglas, and surrounding counties), schedule your confidential appraisal consultation now.
Estate tax filings operate on strict timelines. The further removed you are from the effective date, the more limited comparable data becomes.
A limited number of estate assignments are accepted each month to maintain reporting precision.
• A structured compliance checklist before report delivery
• Direct coordination with your CPA or estate attorney
• A signed qualified appraiser declaration
• Documentation formatted specifically for federal reporting
Secure your appointment before your filing window closes.
February 14th 2026 12:30pm