@fanfare can you cite authority for the proposition that "an appraisal for tax purposes has to be signed by a qualified professional appraiser" in the I.R.C. 1014 context? (Inherited DOD FMV for basis).
I was under the impression that "qualified appraisal" is a defined term in I.R.C. 170(f)(11)(E) and is certainly required for charitable deductions > $5k per 170(f)(11)(C), but not required elsewhere in the code.
See e.g. https://www.dsda.com/News-Publications/Press-Room/56275/Qualified-Property-Appraisers-for-Estate-Tax...
which says "Although not mandatory, it is recommended that appraisals obtained for establishing values of estate assets meet the IRS requirements for a qualified appraisal."
I can find practitioners recommending qualified appraisals for other tax matters. Obviously the burden is on the taxpayer to prove any number on a tax return and a qualified appraisal might be very helpful in meeting that burden, but without authority I don't think it is a requirement outside of charitable deduction domain.
While we're at it, I seem to recall (but can't find quickly find authority for it) that professionals must have "substantial authority" for a tax return position but that taxpayers must only have a "reasonable position" to avoid understatement penalties, where substantial authority is higher burden. Is that right?
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