Guide
Who may sign: qualified appraiser requirements
Updated
Most of the time, who signs a valuation is a question of credibility. For a charitable contribution of a business interest it is a question of eligibility, and the test is objective enough to fail on paper.
The definition
26 CFR 1.170A-17(b) defines a qualified appraiser as an individual with verifiable education and experience in valuing the type of property.
Verifiable is the operative word. The regulation is not asking whether the appraiser is capable; it is asking whether their qualification can be checked by somebody reading the report.
Two routes
Either successfully completed professional or college-level coursework, together with two or more years of experience in valuing the type of property being valued.
Or earned a recognised appraiser designation. The designation route is why credentialed appraisers dominate this work: it settles the eligibility question in one line rather than in an argument about coursework.
The type of property matters
Both routes are tied to the type of property being valued. Experience valuing real estate is not experience valuing a closely held business interest, and the regulation asks about the type in front of you.
That is worth checking before engagement rather than after, because it is checkable and because it is the kind of defect that survives into an examination unchanged.
Dates, which fail more often than qualifications
The appraisal must be signed no earlier than 60 days before the date of the contribution and no later than the due date of the return including extensions, and the valuation effective date must be no earlier than 60 days before the contribution.
A report commissioned early, in the interests of being organised, can fall outside that window. So can one commissioned late and dated to look timely, which is a different and much more serious problem. Fixing the sequence costs nothing if it is planned; it cannot be fixed afterwards at all.