IRS-Defensible Valuations for HNW Estates & Trusts.
Treasury Regulation § 20.2031-1 & IRC § 6695A Qualified Appraisers
Engineered specifically for estate planning attorneys, CPAs, trustees, and family offices managing high-net-worth real estate assets across New York City.
High-Net-Worth estate and trust tax filings demand precision data that withstands federal audit scrutiny. We deliver retrospective Date-of-Death (DoD) narrative reports, fractional interest discount analysis, and step-up in basis valuations accepted by the IRS and estate courts.
Estate Tax Valuation Protocol
- check_circleDate-of-Death Retrospective Comps: Historical ACRIS title and spatial sales comp retrieval matching exact date of decedent passing.
- check_circleStep-Up in Basis Optimization: Minimizing capital gains tax exposure for heirs and successor trustees.
- check_circleFractional Interest Discounts: Empirical valuation of minority interest & lack of marketability discounts for family limited partnerships (FLPs).
3 Pillars of HNW Estate & Trust Valuation
High-net-worth real estate holdings cannot be valued with standardized mortgage templates. We deploy empirical historical data, income capitalization, and USPAP narrative standards.
Date-of-Death (DoD) Appraisals
Determining historical market value as of the exact date of a decedent's passing. We pull historical ACRIS deed recordings, market capitalization rates, and comparable sales matching the target date.
- checkHistorical market capitalization analysis
- checkIRS Form 706 Schedule A formatting
Fractional Interest Discounts
Valuing partial ownership shares in real estate LLCs, trusts, and family limited partnerships (FLPs). Applying empirical data for lack of control and lack of marketability adjustments.
- checkMinority interest discount substantiation
- checkLack of marketability (DLOM) analysis
Step-Up in Basis Valuations
Establishing defensible tax basis adjustments under IRC § 1014. Protecting beneficiaries from inflated future capital gains tax when selling inherited residential or commercial real estate.
- checkIRC § 1014 basis step-up documentation
- checkAudit-tested narrative report structure
IRS Audit Defense & USPAP Compliance Protocol
Every estate tax report prepared by Accurate Appraisals conforms to statutory tax codes, Treasury Regulations, and strict USPAP ethical and reporting rules.
USPAP Ethics Rule (Conduct & Non-Bias)
Independent Valuation Standard- checkZero Contingent Compensation: Appraisal fees are never contingent upon an outcome, targeted estate value, or tax result.
- checkStatement of Absolute Non-Bias: Disinterested 3rd-party status certified under oath for IRS and legal submission.
- checkConfidentiality Rule: NDA-level client data protection under USPAP Ethics and Bank Secrecy standards.
USPAP Standards Rules 1 & 2 (Development & Reporting)
Audit-Resilient Narrative Structure- checkStandards Rule 1-4 (Development): Empirical income capitalization (DCF), cost-depreciation, and sales comp reconciliation.
- checkStandards Rule 2-2(a) Narrative Reporting: Comprehensive documentation disclosing all extraordinary assumptions.
- checkJurisdictional Exception Rule: Seamless invocation when municipal or tax statutes supersede standard rules.
| Valuation Parameter | Statutory Standard | Accurate Appraisals Protocol | IRS Document Code |
|---|---|---|---|
| Fair Market Value Definition | Treas. Reg. § 20.2031-1(b) | Market-clearing price definition under willing buyer/seller arm's length parameters | IRS Form 706 Schedule A |
| Valuation Effective Date | IRC § 2031 / IRC § 2032 | Direct historical comp retrieval matching date of death or 6-month alternate date | IRS Form 706 Section 4 |
| Qualified Appraiser Status | IRC § 6695A | Certified General / Certified Residential license verification and formal CV inclusion | Treas. Reg. § 1.170A-17 |
| USPAP Record Keeping Rule | USPAP Ethics Rule (5-Yr Mandate) | Encrypted digital archive retention for minimum 5 years (2 years post-litigation) | USPAP Ethics Rule |
| USPAP Competency Rule | USPAP Competency Mandate | Prior geographic, market sector, and asset class experience verified prior to engagement | USPAP Standards Rule 1-1 |
| Scope of Work Rule | USPAP Scope of Work Rule | Explicit disclosure of research depth, physical inspection parameters, and data sources | USPAP Standards Rule 2-2 |
HNW Property Portfolio Coverage
Our senior lead appraisers (George Walsh and Logan Walsh) personally conduct physical inspections and author narrative reports for high-value real estate holdings across New York:
Manhattan Gold Coast
Luxury cooperatives, penthouses, high-rise condominiums, and historic townhouses in Upper East Side, Tribeca, and Soho.
Brooklyn Historic Belts
Multi-family brownstones, luxury warehouse lofts, and townhomes in Brooklyn Heights, Park Slope, and Cobble Hill.
Staten Island Luxury Enclaves
Custom hilltop estates, architectural mansions, and prime waterfront parcels in Todt Hill, Lighthouse Hill, Tottenville, and Prince's Bay.
Commercial & Mixed-Use
Retail corridors, commercial office towers, industrial logistics parks, and development air rights across Staten Island and NYC.
Surrounding Enclaves
High-value waterfront estates and residential properties in the Hamptons (Suffolk), Westchester, and Nassau County.
"When managing an estate tax audit or trust valuation, legal representatives require absolute clarity. My son Logan and I author narrative reports designed to meet Treasury Regulations line-by-line."
Request an Estate or Trust Valuation Briefing
Speak directly with George Walsh or Logan Walsh regarding your estate tax timeline, property parameters, and IRS Form 706/709 filing requirements.