IRS appraisal rules: what you need to know before gifting or donating noncash assets

Are you thinking about donating a piece of real estate to your alma mater? Gifting a rare collection to your children? Or transferring a valuable classic car to a charity auction? These types of noncash gifts can be a meaningful way to support a cause, preserve family wealth, or reduce estate tax burdens. 

But, unlike writing a check, donating or gifting valuable assets comes with extra steps. If you don’t properly document their value, the IRS could deny your deduction, challenge your tax return, or even impose penalties. 

A professional appraisal isn’t just a formality—it’s your best defense against IRS scrutiny and the key to ensuring your generosity pays off the way you planned. 

Why Appraisals Matter

An appraisal justifies the fair market value of a donated or gifted asset for tax purposes. This valuation is the backbone of your paperwork when claiming a charitable deduction or reporting gifts. 

Without solid documentation, the IRS could challenge your valuation in one of two ways: 

• If you overstate the value of a donation, you could face penalties for inflating deductions. If the IRS determines that you’ve significantly exaggerated an asset’s worth, they can reduce or deny your deduction and impose a valuation misstatement penalty - which starts at 20% of the underpaid tax and can reach 40% in extreme cases. 

• If you understate the value of a gift, you might trigger penalties for underreporting. Some taxpayers intentionally undervalue gifted assets to reduce gift tax liability. However, if the IRS finds that the reported value is 65% or less of fair market value, they can impose penalties similar to those for overstatement. 

In either case, a proper appraisal helps protect you. It ensures you’re claiming the right tax benefits without drawing unwanted IRS attention. 

When the IRS requires an appraisal

Not all noncash gifts require an appraisal, but for high-value assets, the IRS has strict rules—whether you’re donating to charity (for a tax deduction) or gifting assets to family (for estate planning purposes).

Appraisal requirements for noncash charitable donations (deductions)

If you’re donating property to a qualified charity and plan to deduct the value on your tax return, the IRS has clear documentation thresholds:

• $250 or more – You’ll need a written acknowledgment from the charity, but no appraisal is required.

• $500 or more – You must file IRS Form 8283, Section A, describing the donated asset.

• More than $5,000 – A qualified appraisal is required, and you must complete Section B of Form 8283, which includes your appraiser’s signature.

• More than $20,000 (for artwork) – You must attach a copy of the qualified appraisal to your tax return.

• More than $500,000 – You must attach the full appraisal report to your tax return.

Publicly traded securities generally do not require an appraisal since their fair market value is easily verified. However, privately held business interests, real estate, and collectibles typically do.

Appraisal requirements for gifts to family or others (gift tax rules)

If you’re gifting an asset to family, friends, or a trust, the IRS doesn’t allow you to deduct the value—but an appraisal is still necessary in many cases to determine gift tax liability.

• Gifts exceeding $19,000 (2025) per recipient – These count against your annual exclusion, but no appraisal is required unless challenged.

• Gifts exceeding your remaining lifetime exemption ($13.99 million in 2025) – These may trigger gift tax, making a qualified appraisal critical to justify the valuation.

• Closely held business interests, real estate, or unique assets – The IRS often scrutinizes these, and undervaluation (to reduce gift tax) could result in penalties.

IRS scrutiny and the statute of limitations

For gifts, the IRS typically has three years from the date you file a complete and properly disclosed gift tax return to audit the valuation of a gifted asset. 

But the clock doesn’t start unless the gift is adequately disclosed. That means providing a thorough description of the asset, the method used to determine its value, and any supporting documentation - like a professional appraisal. If you skip this step or submit vague details, the IRS could argue that the statute of limitations never started, keeping your gift open to challenge indefinitely. 

For noncash charitable contributions, the IRS doesn’t necessarily follow the same strict three-year rule that applies to adequately disclosed gifts. While they generally have three years to audit a tax return, they can still challenge the valuation of a donated asset beyond that period if they later uncover fraud, substantial errors, or valuation misstatements. If the deduction was significantly overstated, the IRS may impose valuation misstatement penalties even years later. And in cases of fraud or willful misrepresentation, there is no statute of limitations (SOL), meaning the IRS can audit and challenge the deduction indefinitely.

For gifts, the three-year rule offers stronger protection if the gift is properly disclosed on Form 709. However, the IRS can extend the audit window to six years if they determine that more than 25% of total taxable gifts were omitted, and if a gift is never reported or is fraudulently undervalued, the IRS can challenge it at any time.

Bottom line: While both gift and charitable deduction valuations can be challenged beyond three years, the IRS has more frequent opportunities to extend the SOL for charitable deductions, particularly when there are substantial misstatements or fraud is suspected. Proper documentation is critical in both cases to limit future IRS scrutiny.

How to stay compliant

Avoiding these pitfalls is simple if you take the right steps upfront:

1. Choose a qualified appraiser. The IRS doesn’t accept just any valuation—your appraiser must have expertise in the specific type of asset you’re gifting. They should also have a professional appraiser designation or equivalent education and experience, no conflict of interest, and regular experience in valuing similar assets. 

2. Get the appraisal before filing your tax return. Don’t wait until the last minute. You need time to ensure everything is properly documented.

3. Attach the required forms. Whether it’s an appraisal summary on Form 8283 (for donations) or properly documented valuations for gift tax reporting (Form 709), make sure your paperwork is complete.

4. Keep detailed records. Maintain copies of all appraisals, tax filings, and correspondence related to your gifts or donations. If the IRS asks questions later, you’ll be prepared.

Planning ahead

IRS penalties are expensive, time-consuming, and entirely avoidable. If you’re making substantial noncash gifts or donations, don’t leave valuations to chance. Work with a qualified appraiser, follow IRS requirements, and keep thorough records.

If you’re unsure whether your gifts require a formal appraisal—or need guidance on the best strategy for tax efficiency -  contact our office. A little due diligence now can save you a lot of stress (and money) later.