BUILT FOR THE EXAMINER · Part 1 of 3
Subtitle: Two things changed for 2026 — and one of them is easy to get wrong. What counsel and CPAs should verify before a casualty loss number goes on a return.
This is the first of three editions on how the IRS reads a valuation. Part 1 takes up casualty losses, and what has to exist in the file before a number goes on a return. Part 2 turns to what the Service and the Tax Court actually look for, organized around the ways valuations fail: cash flow models untethered from comparable sales, highest-and-best-use conclusions that collapse under one of the four tests, sale histories left unmentioned, and outside expert reports adopted without being tested. Part 3 takes up the enforcement architecture now being rebuilt around conservation easements and charitable land donations, and asks where the pressure moves next. Each edition stands alone; together they run from one file to the whole system.
On August 19, 2026, the IRS stood up a new office devoted to a category of deduction that turns entirely on appraisals, and said it would work with Treasury on measures to "promote consistent tax administration, and strengthen valuation integrity." The subject of that announcement is taken up in Part 3. The signal is what matters here: the Service is organizing itself around the quality of the valuations it receives.
Which brings us to the deduction most advisors will actually meet. A casualty loss arrives through a client's worst week rather than a planning conversation, and it runs on the same machinery — the same before-and-after arithmetic, the same evidentiary standards, and the same reviewer. This edition is about what counsel and CPAs should verify before a casualty loss number goes on a return.
Key takeaways for counsel and advisors
- Two things changed for 2026, and one of them is easy to get wrong. Public Law 119-21 §70109 made the personal casualty loss regime permanent — the 2018–2025 sunset is gone — and extended it to state-declared disasters for tax years beginning after December 31, 2025. But the statute defines a state declared disaster as one determined by the Governor and the U.S. Secretary of the Treasury, and as of today no Treasury or IRS guidance explains how that concurrence happens. A governor's declaration is not self-executing.
- The appraisal is half the file, and the half that fails first. The valuation professional develops fair market value immediately before and immediately after. Adjusted basis, insurance offsets, the per-casualty floor, and the AGI limitation are tax computations. In Richey v. Commissioner, T.C. Memo. 2023-43, a claim exceeding $820,000 produced a deduction of zero — not because the storm did no damage, but because no before-and-after appraisal was ever obtained, the repair receipts included a swimming pool, and the value decline the taxpayers pointed to was buyer fear of future storms.
- General market decline is not casualty loss — with a caveat that depends on the circuit. Treas. Reg. §1.165-7(a)(2)(i) requires the appraisal to isolate any "general market decline affecting undamaged as well as damaged property." The Ninth Circuit and the Tax Court require physical damage. The Eleventh Circuit, in Finkbohner, allowed a deduction for permanent buyer resistance after neighboring homes were demolished — and the Tax Court has expressly declined to follow it outside that circuit.
- The safe harbors have not moved since 2017. Rev. Proc. 2018-08's thresholds — $20,000 for estimated repair cost, $5,000 de minimis — are unchanged, confirmed still current in the 2025 edition of Publication 547. Most real files fall outside them and into a supported valuation.
A fact pattern counsel will recognize
A declared disaster passes through a coastal county in September. A client's property — a residence on acreage, or a small marina, or a family farm with equipment sheds and a decades-old citrus block — takes real damage. The insurance adjuster comes and goes. The client hires a contractor, who is busy, and who quotes a number that reflects how busy he is. Repairs start; some of them are improvements, because if you are rebuilding a kitchen you may as well rebuild it properly.
In February the CPA asks for a casualty loss number. By then the property has been partially repaired, the pre-storm photographs are on a phone that has since been replaced, the adjuster's report is somewhere in an email thread, and nobody has written down what date the loss is measured on.
Every one of those facts is recoverable in September and expensive in February. That gap is the entire subject of this article.
Beyond the Core Four focuses on specialized properties that fall outside the traditional industrial, retail, multifamily, and office categories. The newsletter examines how value, risk, and utility are shaped by the operational realities of assets such as quarries, marinas, agricultural facilities, processing plants, water-dependent operations, and other complex property types where the real estate is only part of the story.
Where the authority actually lives
Publication 547 is the document everyone reaches for, and it is the wrong one to argue from. The hierarchy runs the other way: Treasury regulations interpret and implement the Code and generally bind; IRS publications explain the rules in plain language for taxpayers and preparers and are informational, not precedential; the Internal Revenue Manual tells IRS personnel how to administer and enforce. A position that rests on publication language alone, against a regulation that says something more specific, is a position resting on the weakest authority in the stack.
For casualty losses the operative texts are IRC §165 and Treas. Reg. §1.165-7. Publication 547 is the map. The regulation is the terrain.
The calculation, and the two halves of the file
The deduction is built in three steps: adjusted basis immediately before the event; the decrease in fair market value, measured as value immediately before minus value immediately after; and the loss, which is the lesser of those two, reduced by insurance or other reimbursement received or reasonably expected.
The division of labor is cleaner than it looks. The valuation professional develops the before-and-after opinion, supports it, and documents it. Basis, reimbursement offsets, the $100 per-casualty floor, the 10%-of-AGI limitation, and the return position are accounting and tax work. Both halves must exist, and neither substitutes for the other. A striking share of examination friction traces to a file where one half was simply assumed — most often an appraisal that reports a value decline without any adjusted basis, filed by a taxpayer who believes the appraised decline is the write-off.
Two structural rules catch owners by surprise.
The single-item rule. For personal-use real property, Treas. Reg. §1.165-7(b)(2)(ii) treats the improvements — "buildings and ornamental trees and shrubbery" — as "an integral part of the property," with no separate basis apportioned. Land, dwelling, and landscaping are one item, and the before-and-after test runs against the whole parcel. A client who lost nineteen mature producing citrus trees has suffered a real loss and may still have very little deduction, because the question is not what the trees were worth but what the parcel was worth with them and without them. Business and income-producing property is measured differently — by the single identifiable property damaged or destroyed — which is one reason the trade-or-business characterization deserves attention early.
Ownership, not possession. In Taylor v. Commissioner, a Summary Opinion from early 2025 and therefore not precedent, a taxpayer claimed $49,500 for Hurricane Harvey damage to a Texas property he had transferred to his adult daughters in 2012. He did not live there. He paid for the repairs and the insurance anyway. The deduction was denied on summary judgment: a casualty loss belongs to the owner of the property at the time of the loss. For estate planners the lesson is compact — after the transfer, intra-family repair spending buys a deduction for nobody.
The two questions that decide the file
What date is this measured on?
Neither the regulation nor the publication fixes an interval for "immediately before" and "immediately after." In practice, "immediately after" means the property in its damaged condition, before repairs and before subsequent market changes unrelated to the casualty.
That is more workable than it sounds. A single effective date with a disclosed hypothetical condition for the before value is defensible. Two dates bracketing an event that genuinely spanned days is defensible. For a federally declared disaster, the declaration date is a natural anchor. What is not defensible is a file in which the demarcation line was never drawn and nobody agreed where it fell.
Sequential events complicate this honestly rather than artificially. A wildfire that takes the barn and garage on the tenth and, after a wind shift, the house on the fifteenth may be two losses on two dates, with the second measured against a property already diminished by the first. That is an unusual file and it should be flagged as one, in writing, at engagement — not discovered two years later when an examiner asks.
Practical instruction for counsel: confirm the effective date or dates in the engagement letter, and have the client acknowledge them. It costs a sentence.
Whose decline is this?
After a widespread event, the whole regional market can soften. Buyers become resistant; reputation moves; prices fall on undamaged property too. That decline is not casualty loss, and the regulation says so expressly — the appraisal "must recognize the effects of any general market decline affecting undamaged as well as damaged property which may occur simultaneously with the casualty, in order that any deduction under this section shall be limited to the actual loss resulting from damage to the property." Publication 547 states the same rule in plainer words: "A decrease in the value of your property because it is in or near an area that suffered a casualty, or that might again suffer a casualty, isn't to be taken into consideration."
An after-value opinion that quietly absorbs the market-wide component overstates the deduction, and it is a straightforward thing for a reviewer to detect.
This is also where the law is less settled than the publication suggests, and the difference is worth knowing before advising a client. In Pulvers v. Commissioner, 407 F.2d 838 (9th Cir. 1969), a landslide destroyed three neighboring homes and did no physical damage to the taxpayers' property; the deduction failed because "or other casualty" means "something like those specifically mentioned," and each listed casualty "surely involves physical damage or loss of the physical property." The Tax Court took the same line in Chamales v. Commissioner, T.C. Memo. 2000-33 — the case of the residence next door to O.J. Simpson's, where a $751,427 claim built on an estimated 30% devaluation was rejected because "only those losses are deductible which are the result of actual physical damage to the property."
But in Finkbohner v. United States, 788 F.2d 723 (11th Cir. 1986), the Eleventh Circuit allowed a deduction for permanent buyer resistance after flooding led the municipality to demolish seven of twelve neighboring houses — "the permanent removal of seven out of twelve neighboring houses is a permanent change" — distinguishing it from resistance "imputable to any informed fear of future damage." Chamales acknowledged Finkbohner and declined to extend it, following Ninth Circuit law under Golsen. No published acquiescence or nonacquiescence has been located, and no later Eleventh Circuit decision revisiting it was found.
The practical upshot: a client in the Eleventh Circuit whose loss rests on permanent, physically caused neighborhood change is in a materially different position from one arguing that buyers are nervous. Both arguments look the same in a first conversation. Only one of them travels.
Proving the loss
The taxpayer bears the documentation burden, and an appraisal cannot cure a missing fact by adopting the owner's account of it.
Richey is the case to read on this, because it fails on nearly every axis at once. Winter Storm Stella damaged a Stone Harbor, New Jersey waterside home and a forty-foot boat in March 2017. The taxpayers claimed over $820,000. The Tax Court allowed nothing. They "did not get an appraisal of their own home valuing it before and after the storm." A realtor was consulted after the examination opened; "what we got were photographs of MLS printouts," which the court described as "a post hoc rationalization" of the couple's own initial estimate. Of $250,875 in repair receipts, roughly $51,600 was pool installation and an enhanced bulkhead — improvements, not restoration. There was no documentation of the pre-storm condition, so no one could test whether the repairs were necessary. Active insurance policies were never claimed against. The boat had neither an appraisal nor damage documentation.
None of those failures required expertise to avoid. All of them required somebody to act in the first month.
Assemble before the valuation is ordered: before-and-after photographs and video, drone footage where available; the insurance adjuster's report and the claim file; structural or engineering reports where foundations or systems are at issue; contractor estimates and paid invoices, separated between restoration and improvement; prior appraisals, including any recent refinance appraisal; MLS listing and sale history for the subject; property condition reports; assessment records and any assessment protest; and a documented owner interview with dates, sequence, and condition.
Where a material fact genuinely cannot be verified, an extraordinary assumption is the disclosure device — and the Uniform Standards of Professional Appraisal Practice (USPAP), the rule book every licensed and certified appraiser in the United States is bound to work under, requires a reasonable basis for one. It is a label for a gap, not a substitute for closing it.
Two further points deserve their own space.
Photographic evidence is now trivially fabricable. The discipline is simple and should become routine: ask the client, in writing, whether any image has been generated or enhanced, and document the answer. That question protects the appraiser, the preparer, and the client, and there is every reason to expect it to migrate into the audit file.
Scope cannot be trimmed because the IRS is the intended user. When a client says a report is for a return, the Service becomes a reader of that report. The instinct to shorten — the client knows the property, why belabor it — is precisely backwards. The reader who matters knows nothing about the property, was not there, and will not accept assertion in place of support.
Repairs, safe harbors, and a set of thresholds that stopped moving
The cost-of-repairs method is acceptable evidence of the decrease in fair market value only if four conditions are met: the repairs are necessary to restore the property to its condition immediately before the casualty; the amount spent is not excessive; "the repairs do not care for more than the damage suffered"; and post-repair value does not, as a result of the repairs, exceed pre-casualty value. Richey's pool and bulkhead failed two of the four. "We fixed it and upgraded while we were in there" is a common and expensive answer.
Rev. Proc. 2018-08 supplies seven safe harbors. For personal-use residential real property: Estimated Repair Cost (loss of $20,000 or less, using the lesser of two estimates from separate, independent, licensed or registered contractors); De Minimis ($5,000 or less, good-faith estimate with records of the methodology); Insurance (no cap, using the insurer's estimated loss); Contractor (no cap, federally declared disasters only, binding signed contract); and Disaster Loan Appraisal (no cap, federally declared disasters only). For personal belongings: De Minimis ($5,000 or less in the aggregate) and a Replacement Cost method for federally declared disasters, which reduces the replacement cost of a new item by 10% per year of ownership, floored at 10%, must be applied to all belongings for that disaster, and excludes boats, aircraft, mobile homes, trailers, vehicles, antiques, and anything that holds or gains value.
Those thresholds were set in 2017 and have not been increased. Nothing has superseded them; Publication 547 for 2025, printed in February 2026, still states $20,000 and $5,000. After nine years of construction cost inflation the practical consequence is worth stating plainly: for most damaged real property in most markets, the safe harbors do not reach, and the file needs a supported valuation.
The categories, and what changed for 2026
Publication 547 distinguishes three categories, and they nest rather than sit side by side. A federal casualty loss — a personal-use loss attributable to a federally declared disaster — is the gateway to deductibility. A disaster loss is the class eligible for the §165(i) election. A qualified disaster loss is the narrower, congressionally enumerated subset carrying the enhanced treatment: a $500 floor instead of $100, no 10%-of-AGI reduction, and deductibility without itemizing. A Stafford Act declaration alone does not create a qualified disaster loss.
The §165(i) election allows a federally declared disaster loss to be taken on the immediately preceding year's return. The deadline is not in the statute and is regularly missed: Treas. Reg. §1.165-11(f) sets it at six months after the due date of the disaster-year return, determined without regard to extensions. The IRS's own worked example is unambiguous — for calendar-year individuals, the deadline to elect a 2025 disaster loss on the 2024 return is October 15, 2026.
Then the 2026 change, which is larger than most summaries suggest. Public Law 119-21 §70109, enacted July 4, 2025, did two things. It struck the words ", and before January 1, 2026" from §165(h)(5)(A), making the personal casualty loss regime permanent rather than a provision sunsetting after 2025. And it extended the regime to state-declared disasters, adding a new §165(h)(5)(C) definition. Both apply to taxable years beginning after December 31, 2025.
The definition deserves reading closely. A "State declared disaster" is a natural catastrophe — or, regardless of cause, any fire, flood, or explosion — "which in the determination of the Governor of such State (or the Mayor, in the case of the District of Columbia) and the Secretary causes damage of sufficient severity and magnitude to warrant the application of the rules of this section."
Read "the Secretary" carefully, because it is doing real work in that sentence. Throughout the Internal Revenue Code the term means the Secretary of the Treasury — or, under §7701(a)(11)(B) and (a)(12)(A), his delegate, which in practice means the IRS. It is not the state's own secretary of state, and it is not any other federal department.
The Treasury Secretary's concurrence is a statutory condition, not a formality, and as of today there is no guidance explaining how it is obtained. No notice, revenue procedure, FAQ, or published list addresses §165(h)(5)(C). The IRS's page announcing the change says only that the deduction "may also include losses resulting from state-declared disasters, provided all other requirements under Internal Revenue Code §165 are satisfied." Advisors should not treat a governor's proclamation as sufficient, and should not build a client's 2026 return position on the assumption that it is.
One more caution, because the two are easy to conflate: this is a deductibility provision. The Filing Relief for Natural Disasters Act, which addresses postponement of filing deadlines for state-declared disasters, is a different statute doing a different job.
Why casualty loss valuations fail
The loss an owner feels is not the loss a market prices. The garage that held a lifetime's work; the citrus block a family planted three generations ago; the boat that was the whole point of owning the house. Each is a real loss, and none of them is the measure. Fair market value asks a narrower question — what a hypothetical buyer, with substitutes available, would pay for the property before the event and after it — and the reported cases turn on that gap with real consistency.
| Case | The loss | Claimed | Allowed | What decided it |
|---|---|---|---|---|
| Richey (T.C. Memo. 2023-43) | Storm-damaged shore home and a 40-foot boat | over $820,000 | $0 | No before-and-after appraisal; MLS printouts assembled after the audit opened, described as "post hoc rationalization"; ~$51,600 of $250,875 in receipts was a pool and an upgraded bulkhead; no pre-storm condition evidence; active insurance never claimed |
| Taylor (T.C. Summ. Op. 2025-10) | Hurricane-damaged Texas residence | $49,500 | $0 | The property had been transferred to the taxpayer's adult daughters years earlier. Paying for the repairs is not ownership |
| Chamales (T.C. Memo. 2000-33) | Residence adjoining a notorious crime scene | $751,427 | $0 | The decline came from publicity and buyer sentiment; the property itself was undamaged |
| Pulvers (9th Cir. 1969) | Home beside a landslide that destroyed three others | value decline claimed | denied | "Or other casualty" reaches physical damage or loss; this property was untouched |
| Finkbohner (11th Cir. 1986) | Home in a flooded neighborhood where seven of twelve nearby houses were demolished | value decline claimed | allowed | A permanent, physical change to the neighborhood — not an informed fear of future damage |
Three of those failed on evidence the taxpayer could have preserved in the first month. One failed on a fact that had nothing to do with the weather. Only Finkbohner succeeded, and it succeeded because the change was permanent, physical, and next door — not because buyers had become uneasy. That is the line, and it is narrower than clients expect it to be.
The penalty exposure follows the same logic. An overstated casualty loss can draw the accuracy-related penalty under §6662 — 20% for negligence or a substantial understatement of income tax, and 40% under §6662(h) where the claimed value reaches 200% or more of the correct amount. Reasonable cause under §6664(c)(1) remains available here, which is precisely why a supported appraisal and a documented good-faith investigation are worth what they cost. (Charitable contribution property is governed by a harsher rule, and that is a subject for Part 3.) Appraisers carry their own exposure under §6695A, measured as the lesser of a share of the underpayment or 125% of the fee earned.
Why it matters for RPTE attorneys
Engagement is where the leverage is. There are no do-overs. Unlike a bank appraisal, which can sometimes be corrected before a loan closes, an appraisal supporting a return has been used the moment the return is filed. Reviewers do not send reports back for correction; they either accept the value or develop their own. Everything an attorney can influence — scope, effective dates, document production, the identification of the Service as an intended user — happens before the report is issued.
The engagement letter should anticipate examination. A return-supporting appraisal may generate questions two years out, and an appraiser engaged for a flat fee with no provision for examination support is an appraiser with no obligation and no budget when the questions arrive. Address audit support, file retention, and testimony in the engagement, not after.
Ownership and entity structure decide who may claim. Lessor and lessee, transferred family property, entity-held property, and property subject to a life estate all produce different answers, and Taylor shows how cleanly a deduction can fail on a fact that has nothing to do with the damage.
Documentation is a legal work product problem, not just a valuation one. The evidence that proves a loss is gathered in the days after the event, by people who are not thinking about a return. Counsel who send a short document-preservation instruction in the first week of a declared disaster do more for the eventual deduction than anyone will do in the following year.
Why it matters for CPAs
Confirm the effective date before the valuation is ordered, and confirm it with the client in writing. It is the single cheapest thing in the file.
Watch the market-decline line. If the after value was developed during a regionally depressed post-event market, ask directly how the general decline was isolated. An appraisal that cannot answer that question is not compliant with §1.165-7(a)(2)(i), whatever else it does well.
Separate restoration from improvement in the repair records as they come in, not at filing. Once the receipts are commingled, the burden of unscrambling them falls on the taxpayer.
The §165(i) six-month deadline is not extendable by extending the return. Calendar it from the unextended due date.
For 2026 returns, do not assume a state declaration qualifies. Concurrence by the Secretary of the Treasury is a statutory element and no implementing guidance exists. Where a client's loss depends on a state declaration, document the position and watch for guidance.
Model the multi-year picture. Reimbursement offsets, the §165(i) election, the enhanced qualified-disaster treatment, and the taxpayer's itemizing posture interact, and the best answer is not always the current year.
For owner-users, lenders, and investors
For an owner, the practical lesson is that the deduction is built in the first month and claimed in the fourteenth. For lenders, a post-event collateral position turns on the same before-and-after question, and a value that has absorbed a region-wide decline is a value that will move again. For buyers of damaged assets, the distinction between physical impairment and market sentiment is exactly the distinction that determines whether a discount persists.
A pre-engagement checklist
- Is the disaster federally declared, state-declared, or neither — and for a state declaration in a 2026 or later tax year, is there any basis to believe the Secretary of the Treasury has concurred?
- Who owned the property on the date of loss, and in what capacity?
- Is the property personal-use, business, or income-producing? Has the single-item rule been considered?
- What is the effective date, or dates, and has the client agreed to it in writing?
- Has a document-preservation instruction gone out — photographs, adjuster reports, invoices, condition evidence?
- Have insurance claims been filed, and what has been or will reasonably be received?
- Are repair records separated between restoration and improvement?
- Does any safe harbor actually reach this loss, or is a supported valuation required?
- Has the appraiser been told the IRS is an intended user, and has scope been set accordingly?
- Does the engagement address examination support and file retention?
- If the §165(i) election may be attractive, has the unextended six-month deadline been calendared?
- Have AI-generated or enhanced images been asked about, in writing?
Frequently asked questions
How is a casualty loss valued for tax purposes? By the decrease in fair market value — value immediately before the casualty minus value immediately after — generally established by competent appraisal under Treas. Reg. §1.165-7(a)(2)(i). The deductible loss is the lesser of that decrease or the property's adjusted basis, reduced by insurance or other reimbursement.
What is the difference between a disaster loss and a qualified disaster loss? A disaster loss is attributable to a federally declared disaster and is the class eligible for the §165(i) election to deduct on the prior year's return. A qualified disaster loss is a narrower, congressionally enumerated subset that carries a $500 floor instead of $100, no 10%-of-AGI reduction, and deductibility without itemizing. A Stafford Act declaration alone does not create one.
Can a taxpayer deduct estimated repair costs before the repairs are made? Generally the cost-of-repairs method requires that the repairs actually be made and satisfy four conditions. Rev. Proc. 2018-08 provides limited safe harbors that permit estimates — the Estimated Repair Cost method for losses of $20,000 or less and a de minimis method for $5,000 or less — but their thresholds are low and their conditions are specific.
Does a governor's disaster declaration now support a casualty loss deduction? For tax years beginning after December 31, 2025, §165(h)(5) reaches state declared disasters — but the statutory definition requires the determination of both the Governor and the U.S. Secretary of the Treasury, and no guidance has yet been issued on how that concurrence is made or documented.
The broader lesson
An examiner reviewing a casualty loss is not running a USPAP compliance checklist and is not an underwriter looking for missing initials. The question is narrower and harder: is the fair market value correct, and is the reasoning credible enough to be relied upon. Reports fail when they reach a critical mass of unsupported steps — a value with no comparables behind it, an after value that quietly includes the whole region's bad year, a repair figure with no source, an owner's account adopted as fact.
Which is the same standard that applies in every other valuation this newsletter covers. On a quarry, on a marina, on a processing plant, on a farm — the analysis has to hold up to someone who was not there, has no stake, and will not take the owner's word for anything. In a casualty loss, that reader is guaranteed to exist. The advisors who serve their clients best are the ones who build the file in the first month, for the reader who will open it in the fourteenth.
This is the work our team does: solving complex real estate and personal property problems for clients — untangling what they actually own across land, water, minerals, timber, equipment, and the operating business, and turning that inventory into numbers counsel and advisors can defend. A casualty loss is simply the version of that question asked under a deadline, in the worst possible week.
A question for your practice: When a client calls in the week after a disaster, does your intake start with the tax benefit — or with the evidence that will still exist a year from now?
If a client's holdings raise these questions — a damaged working property, a farm or marina where the real estate and the operation intertwine, a loss that has to be measured rather than asserted — that intersection of complex real estate and personal property is exactly where our team works. If your firm would like a private presentation on these topics, feel free to reach out. We regularly present to law firms and legal teams (including CLE-style briefings), CPA firms and societies (including CPE-style sessions), family offices, owner-users, and industry stakeholders on complex property and specialized asset issues.
Next in the series — Part 2: what the IRS and the Tax Court actually look for in a valuation, and what to demand from one before it goes on a return.
Daniel Boring, CRE®, MAI, ARA, ASA | Senior Vice President – Valuation Advisory Services | Kidder Mathews
Sources and further reading: IRS, Publication 547, Casualties, Disasters, and Thefts and Form 4684 and instructions; Treas. Reg. §1.165-7 and §1.165-11; 26 U.S.C. §165; IRS, Rev. Proc. 2018-08 and Rev. Proc. 2016-53; IRS, Casualty loss deduction expanded and made permanent; IRS, IR-2026-95, Office of Conservation Easements; 26 U.S.C. §6662, §6664, and §6695A; Chamales v. Commissioner, T.C. Memo. 2000-33; Pulvers v. Commissioner, 407 F.2d 838 (9th Cir. 1969); Finkbohner v. United States, 788 F.2d 723 (11th Cir. 1986); IRS, Internal Revenue Manual 4.48.6, Real Property Valuation Guidelines.
Case details, figures, ownership information, and property identifiers have been modified or generalized to protect confidentiality. The discussion is based on real-world appraisal and advisory experience and is presented for educational purposes only. It is not intended as valuation advice, legal advice, tax advice, accounting advice, or investment advice for any specific property, transaction, or dispute.