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