@Krazedav wrote:
Does anyone know where I can find that requirement specified in the IRS documentation.
All over the place and, for your information, I have personal (professional) and direct experience with this issue.
Technically, the IRS is actually not "required" to accept any valuation. but they will almost certainly accept an appraisal from a certified and licensed appraiser. Again, however, the IRS can dispute any valuation assigned by the taxpayer.
There are also IRMs dealing with valuation procedures for various types of property.
Otherwise, see:
https://www.appraisalinstitute.org/IRSAddsQualifiedAppraisertoEstateTaxRules
https://www.prairiecap.com/articles/gift-estate-tax-valuation-pointers-the-importance-of-a-qualified...
https://www.journalofaccountancy.com/issues/2019/may/basis-consistency-requirements-appraisal.html
https://www.law.cornell.edu/cfr/text/26/301.6501(c)-1
https://www.law.cornell.edu/cfr/text/26/1.170A-17
