Who According To IRS Is a Qualified Appraiser? (Art, Antiques, Form 8283)

Learn who the IRS considers a qualified appraiser, what disqualifies an expert, and how to vet an appraisal for Form 8283 with audit-ready checklists and example comps.

Qualified appraiser reviewing a donated item with a jeweler's loupe

Recent auction comps (examples)

To help ground this guide in real market activity, here are recent example auction comps from Appraisily’s internal database. These are educational comparables (not a guarantee of price for your specific item).

Image Description Auction house Date Lot Reported price realized
Auction comp thumbnail for HOWARD PYLE (American, 1853-1911) "'And who's going to support 'em?' demanded Mrs. Barkley", illustration from Old Chester Tales, by Margaret Deland, 1898 Oil on cardboard laid on masonite 17 x 12 in. Signed lower right According to a Statement of (Heritage Auctions, Lot 78151) HOWARD PYLE (American, 1853-1911) "'And who's going to support 'em?' demanded Mrs. Barkley", illustration from Old Chester Tales, by Margaret Deland, 1898 Oil on cardboard laid on masonite 17 x 12 in. Signed lower right According to a Statement of Heritage Auctions 2010-10-15 78151 USD 65,725
Auction comp thumbnail for A 19TH CENTURY JAPANESE MEIJI PERIOD SAMURAI SWORD signed Yoshimichi, with leather scabbard. 92 cm long. Note: According to Hawley's Japanese Swordsmiths (revised), there were 11 generations of swordsmiths in Yamashiro Province who signed with the me (Hannam's Auctioneers, Lot 2101) A 19TH CENTURY JAPANESE MEIJI PERIOD SAMURAI SWORD signed Yoshimichi, with leather scabbard. 92 cm long. Note: According to Hawley's Japanese Swordsmiths (revised), there were 11 generations of swordsmiths in Yamashiro Province who signed with the me Hannam's Auctioneers 2025-10-23 2101 GBP 950
Auction comp thumbnail for § Sir Jacob Epstein K.B.E. (British 1880-1959) First Portait of Kitty (with Curls), conceived 1944 (Lyon & Turnbull, Lot 77) § Sir Jacob Epstein K.B.E. (British 1880-1959) First Portait of Kitty (with Curls), conceived 1944 Lyon & Turnbull 2022-04-29 77 GBP 6,500
Auction comp thumbnail for Twins Seven Seven (1944-2011, Nigeria) Aomerin Joba Ambition, Father of the beast who loves to become human king, 2002 (Piasa, Lot 140) Twins Seven Seven (1944-2011, Nigeria) Aomerin Joba Ambition, Father of the beast who loves to become human king, 2002 Piasa 2021-11-24 140 EUR 1,700
Auction comp thumbnail for Peter NGUGI né en 1978 - Kenya The who is who, 2020 Huile sur toile (Artcurial, Lot 167) Peter NGUGI né en 1978 - Kenya The who is who, 2020 Huile sur toile Artcurial 2021-06-15 167 EUR 13,000
Auction comp thumbnail for Daniel Berkeley Updike, editor. The Altar Book: Containing the Order for the Celebration of the Holy Eucharist According to the Use of the American Church. Boston: D.B. Updike and the Merrymount Press, 1896. (Swann Auction Galleries, Lot 372) Daniel Berkeley Updike, editor. The Altar Book: Containing the Order for the Celebration of the Holy Eucharist According to the Use of the American Church. Boston: D.B. Updike and the Merrymount Press, 1896. Swann Auction Galleries 2025-10-23 372 USD 3,302
Auction comp thumbnail for David Godbold, The World According to De Sade (Rago Arts and Auction Center, Lot 295) David Godbold, The World According to De Sade Rago Arts and Auction Center 2025-09-30 295 USD 250
Auction comp thumbnail for James Arthur O'Connor (1792 - 1841) A wooded landscape with figures on a path Oil on panel, 18.5 x 23.4cm (7¼ X 9¼) Signed Provenance: Sale, Christie's, London, 15 December 1883, lot 161; Martin E.P. Smith, 1902 (according to a label on the r (Adam's, Lot 52) James Arthur O'Connor (1792 - 1841) A wooded landscape with figures on a path Oil on panel, 18.5 x 23.4cm (7¼ X 9¼) Signed Provenance: Sale, Christie's, London, 15 December 1883, lot 161; Martin E.P. Smith, 1902 (according to a label on the r Adam's 2023-09-27 52 EUR 6,500
Auction comp thumbnail for Analia Saban,  Argentinian b.1980 -  Photogram With Hand, 2011;  gelatin silver print on resin coated paper, 78 x 93 cm  Provenance: Praz-Delavallade, Paris (according to the copy of the original invoice);  private collection, purchased from the a (Roseberys, Lot 402) Analia Saban,  Argentinian b.1980 -  Photogram With Hand, 2011;  gelatin silver print on resin coated paper, 78 x 93 cm  Provenance: Praz-Delavallade, Paris (according to the copy of the original invoice);  private collection, purchased from the a Roseberys 2023-06-06 402 GBP 550
Auction comp thumbnail for Law.- Regicides.- [Finch (Heneage, Earl of Nottingham)] An exact and most impartial accompt of the indictment, arraignment, trial, and judgment (according to law) of twenty nine regicides, Printed for … (Forum Auctions - UK, Lot 28) Law.- Regicides.- [Finch (Heneage, Earl of Nottingham)] An exact and most impartial accompt of the indictment, arraignment, trial, and judgment (according to law) of twenty nine regicides, Printed for … Forum Auctions - UK 2022-09-15 28 GBP 800

Disclosure: prices are shown as reported by auction houses and are provided for appraisal context. Learn more in our editorial policy.

If you’re donating art, antiques, collectibles, or other noncash property and planning to claim a charitable deduction, the IRS uses a strict definition of a qualified appraiser. This isn’t a marketing label—it’s a compliance standard tied to whether your deduction is allowed.

This guide explains (in plain English) who the IRS considers qualified, what disqualifies an otherwise skilled expert, what a qualified appraisal must include, and how to vet the appraiser and report before you sign Form 8283.

Quick answer: what the IRS is looking for

For donation-related filings, the IRS expects an appraiser who is competent for your property type, regularly paid for appraisals, independent of the transaction, and able to deliver (and sign) a report that meets IRS “qualified appraisal” content and timing rules.

  • Competence: education + at least two years of experience appraising the type of property.
  • Professional practice: routinely performs appraisals for compensation (not just occasional opinions).
  • Independence: no conflicts and no fees tied to value or deduction outcome.
  • Documentation: a signed report with method + market evidence, and signatures where required (including Form 8283 when applicable).

Qualified appraiser vs qualified appraisal (don’t confuse these)

People often focus on the person, but compliance is a two-part test: the appraiser must meet IRS requirements, and the appraisal report must also meet IRS requirements. You need both.

Requirement What to verify Why it matters
Qualified appraiser Property-type education/experience, compensated practice, independence, no disqualifiers. An otherwise solid value conclusion can be rejected if the signer isn’t “qualified.”
Qualified appraisal Correct timing window, signed report, required descriptions, methods, comps/market evidence, and declarations. Even a qualified appraiser can produce a non-qualifying report if required elements are missing.
Substantiation Form 8283 completion/signatures and (for high-value cases) attaching the appraisal or meeting additional IRS documentation rules. Missing attachments or signatures can put the entire deduction at risk.

Who is not qualified (common disqualifiers & red flags)

A respected curator, dealer, or collector can have real expertise and still be disqualified for IRS purposes due to conflicts. Use this as a screening list.

Red flag Why the IRS may object Safer alternative
The seller/dealer who sold you the item (or an employee/related party) Not independent; the IRS treats parties to the acquisition as conflicted. Use a third-party appraiser with no financial interest in the outcome.
The donee charity (or someone employed by the charity) Conflicts of interest with the donation. Hire an external appraiser; ask the charity for process guidance only.
Fee depends on value (“percentage of appraised value”) Contingent fees undermine independence. Use hourly or flat-fee pricing with a clear scope of work.
“Generalist” claiming to appraise everything Competence must match the property type being appraised. Match specialty to category (e.g., prints, bronzes, silver, rare books).

Form 8283 thresholds (fast cheat sheet)

Donation substantiation depends on value thresholds. The table below is a practical starting point, but confirm current instructions for your tax year and property type.

Situation Common IRS requirement What to plan for
Noncash donation > $5,000 Qualified appraisal + Form 8283 (Section B) Hire the right specialist early; collect photos and documentation.
Single item (art) ≥ $20,000 Additional substantiation (often appraisal attachment) Expect higher scrutiny; use a defensible method + comps.
Donations ≥ $500,000 (certain property) Attach qualified appraisal to return Keep full workfile; assume review is possible.

Checklist: confirming an IRS-qualified appraiser

Use this decision tree when you interview an appraiser. It helps you verify both qualifications and independence.

Decision tree: IRS qualified appraiser screening checklist
Decision tree to screen an appraiser for IRS donation work (Form 8283 situations). Credit: Appraisily (generated).

Practical checklist (questions to ask)

  • Category match: “How many appraisals have you done for this category in the last 12 months?”
  • Credentials: “What coursework/designations support this specialty?”
  • Independence: “Do you buy/sell in this category?” “Any ties to the charity?”
  • Fees: “Is your fee hourly/flat?” (Avoid value-contingent fees.)
  • Report readiness: “Will your report include comps and meet IRS qualified appraisal elements?”
  • Signing: “Will you sign the appraiser declaration and Form 8283 where required?”

What a qualified appraisal report should include (audit-ready)

A qualified appraisal typically reads like a defensible valuation memo: it describes the object in a way another expert could identify it, explains the market and method used, and supports the conclusion with evidence.

Practical tip: Ask for a short sample report outline (with client data removed). You’re checking structure and evidence, not “pretty PDF” design.

  • Identification: maker/artist attribution, materials, dimensions, inscriptions/marks, edition details.
  • Condition & authenticity notes: restoration, damage, replacements, provenance, and any uncertainty disclosures.
  • Valuation approach: what market is relevant, why that market, and which methods were used.
  • Comparable sales (“comps”): similar items, with differences adjusted and explained.
  • Effective date + intended use: donation FMV vs insurance replacement value are not the same.

Example comps: how FMV evidence looks in practice

Below are three real auction results (internal DB) to show the type of evidence a qualified appraisal often cites. Your appraiser should use comps that match your category and explain why each comp is comparable.

Comp Auction details Realized price
Illustrated book (Audebert, primates) Sotheby’s · Lot 3 · 2023-11-28 £15,240 hammer
Modern art (Zdenek Sykora) Koller Auctions · Lot 3470 · 2021-12-02 CHF 400,000 hammer
Painting (Marcel Dyf) Sotheby’s · Lot 211 · 2007-02-15 $15,600 hammer

Comp images (for context)

Auction comp: illustrated book lot image
Sotheby’s lot 3 (2023-11-28) — example book comp. Credit: Appraisily auction DB.
Auction comp: modern artwork lot image
Koller lot 3470 (2021-12-02) — example modern art comp. Credit: Appraisily auction DB.
Auction comp: painting lot image
Sotheby’s lot 211 (2007-02-15) — example painting comp. Credit: Appraisily auction DB.

Photo pack: what to photograph for the appraiser

Even the best appraiser can’t defend FMV without good identification and condition evidence. Use the gallery below as a quick checklist of the kinds of details that typically matter in art and antiques appraisal work.

Inspection cues (gallery)

Raking light technique on a painting surface
Raking light reveals texture and repairs. Credit: Appraisily (generated).
Macro photo of a hallmark on an antique object
Hallmarks/maker marks help identify property type and origin. Credit: Appraisily (generated).
Close-up of an artist signature detail
Signature details (and how they sit in varnish/wear) can matter. Credit: Appraisily (generated).
Edition number area on a limited edition print
Edition numbers should be photographed clearly for prints. Credit: Appraisily (generated).
Foundry stamp on a bronze sculpture base
Foundry stamps and casting details are key for bronzes. Credit: Appraisily (generated).
Casting seam and chasing marks on bronze
Casting seams/chasing can indicate production method and quality. Credit: Appraisily (generated).
Sprue plug on underside of a cast sculpture
Sprue plugs (underside) help experts evaluate casting. Credit: Appraisily (generated).
Comparison of natural patina versus over-polished surface
Patina vs polish: condition and originality cues that affect value. Credit: Appraisily (generated).

Short FAQ

Does USPAP compliance automatically make an appraiser “qualified” for the IRS? Not automatically. USPAP is a quality baseline, but the IRS definition also focuses on property-type competence, independence, compensated practice, and meeting the qualified appraisal content/timing requirements.

Can a dealer write the appraisal? Dealers often know the market, but they may be conflicted—especially if they sold the piece, want to buy it, or charge contingent fees. A qualified appraisal should be independent.

Do I need comps in the report? In most categories, market evidence (including comps) is a core way to support FMV. The report should explain why the comps are comparable and how differences were handled.

Search variations collectors ask

Readers often Google:

  • who is considered a qualified appraiser for IRS Form 8283
  • IRS qualified appraiser requirements for art donation over 5000
  • what disqualifies an appraiser for charitable contribution appraisal
  • does a USPAP appraiser count as IRS qualified appraiser
  • can a dealer appraise an item for tax donation purposes
  • what must a qualified appraisal include for IRS donation
  • how to vet a qualified appraiser for antiques donation
  • Form 8283 appraisal date within 60 days rule explained

Each question is addressed in the guide above—use it as a pre-signing checklist.


This article is educational and focuses on charitable-contribution appraisal standards. For tax decisions, consult your tax advisor and ensure your appraiser’s qualifications and report match the latest IRS rules for your filing year.

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