Who According To IRS Is A Qualified Appraiser

If you collect antiques or fine art, the phrase “qualified appraiser” matters most when you claim a charitable deduction for donating objects, and it can also influence how your valuations hold up during an IRS review. The IRS has a precise, technical definition of a qualified appraiser and a qualified appraisal. Get either one wrong and your deduction can be denied—even if your value estimate was reasonable.

This guide translates the IRS standards into plain language for art and antiques owners, collectors, and advisors.

Why “qualified appraiser” matters

• Charitable contributions of noncash property over $5,000 generally require a qualified appraisal prepared and signed by a qualified appraiser. You’ll also file Form 8283, Section B.
• For high-value art and antiques (for example, single items over $20,000), you face extra substantiation requirements and potential review by the IRS Office of Art Appraisal Services.
• Beyond donations, these standards set a credibility baseline for valuations used in estate planning, insurance scheduling, and equitable distribution. While the exact statutory requirements differ across tax contexts, the IRS definition is the safest benchmark to aim for.

Bottom line: A qualified appraiser is about credentials, experience with your specific type of property, independence, and correct documentation.

The IRS definition, in plain English

The core IRS rule: A qualified appraiser is an individual who has verifiable education and experience valuing the type of property being appraised, regularly performs appraisals for compensation, is independent of the transaction, and is not otherwise disqualified. The appraisal must be a “qualified appraisal” containing specific content and timing elements.

What “qualified appraiser” means for antiques and art:

• Education and experience match the property type
  • The appraiser has completed professional-level education in valuing the category at issue (e.g., fine art paintings, decorative arts, furniture, silver, ethnographic art, rare books) and has at least two years of experience appraising that type of property.
• Recognized credential or equivalent education
  • Either the appraiser holds an appraisal designation from a recognized professional appraiser organization or has completed appropriate coursework and amassed the required experience to meet IRS minimums.
• Appraises for compensation on a regular basis
  • The person routinely performs paid appraisals, not just an occasional valuation for a friend or employer.
• Independence and no prohibited fees
  • The fee cannot be contingent on the value or the outcome. Flat or hourly fees are typical.
• Not an excluded person
  • The appraiser is not the donor, the donee organization, or a party to the transaction in which the donor acquired the property (such as the dealer who sold it to the donor), nor an employee or related party of those persons. The appraiser also must not be barred from practice before the IRS during the three-year period ending on the appraisal date.

What “qualified appraisal” means:

• Timing
  • The appraisal is dated no earlier than 60 days before the donation and no later than the due date (including extensions) of the return on which you claim the deduction.
• Content
  • A complete, signed report that includes: a detailed description of the item, condition, date of contribution, appraisal date (effective date), fair market value, the valuation method and analysis, a statement of the appraiser’s qualifications, and the appraiser’s identifying number. It must be prepared for income tax purposes and contain the appraiser’s declaration acknowledging potential appraiser penalties for misstatements.
• Form 8283
  • For property valued over $5,000, you must attach Form 8283, Section B, signed by both the appraiser and the donee. For certain high-value art, you will attach a copy of the signed appraisal to the return as well.

These requirements come from the Internal Revenue Code and Treasury Regulations governing charitable contributions of property, particularly the regulations under section 170 and related IRS guidance.

Education, experience, and credentials the IRS accepts

The IRS looks for verifiable, property-specific competence:

• Appraisal designation from a recognized professional organization
  • Examples of recognized art/antiques organizations include major national appraisal bodies. Designations typically require education, experience, and testing.
• Or, coursework plus experience
  • Absent a designation, the appraiser must show successful completion of professional-level coursework in valuation principles relevant to the type of property and at least two years of experience appraising that property type.
• Property-type specificity
  • “Type of property” is not a vague label. An appraiser experienced in residential real estate is not qualified to appraise a 19th-century American painting for IRS purposes. Likewise, a fine art specialist may not be qualified for a rare musical instrument, unless they can document education and experience in that specific category.
• USPAP familiarity
  • Many qualified appraisers follow the Uniform Standards of Professional Appraisal Practice (USPAP). While IRS rules don’t mandate USPAP per se, USPAP compliance is a strong signal that the report will contain the required content and credible methodologies.

Practical tip: When interviewing an appraiser, ask for a short qualifications statement tailored to your category—e.g., “20th-century European paintings,” “American Federal furniture,” “Chinese ceramics,” or “Art Deco silver.”

Who is not a qualified appraiser (common disqualifiers)

The IRS specifically excludes certain people to avoid conflicts of interest and abuse:

• The donor, the donee charity, or an employee of either.
• Any party to the transaction in which the donor acquired the property (often the dealer or gallery who sold it to the donor) and certain related parties or employees of those parties.
• Someone related to the donor or donee under tax-law related-party rules.
• Anyone who charges a prohibited contingent fee (contingent on assigned value or deduction).
• A person prohibited from practice before the IRS during the three-year period ending on the appraisal date.

In short: Independence is non-negotiable. The person who sold you the piece, your close relative, or the recipient charity cannot be your qualified appraiser for the donation.

Special rules and nuances for art and antiques

Antiques and art raise a few additional considerations:

• Value thresholds that trigger extra steps
  • Over $5,000 (generally): Qualified appraisal and Form 8283, Section B.
  • Over $20,000 (single item of art): Attach a complete signed copy of the appraisal to your return. Be prepared to provide high-quality photographs upon request. The IRS Office of Art Appraisal Services may review.
  • Over $500,000 (any property): Attach the appraisal to the return even if not art.
  • Optional Statement of Value (art $50,000+): You may request a Statement of Value from the IRS for a fee. This can provide advance certainty, though it’s a separate submission process.
• Market-specific methodology
  • For antiques and art, fair market value depends on the most relevant market (retail gallery, dealer, auction) for a willing buyer and willing seller, neither under compulsion, and both informed. The appraiser should justify the chosen market with data.
• Condition and authenticity
  • Reports should address condition, restorations, signatures/marks, provenance, and authenticity indicators. If a work’s attribution or authenticity is uncertain, the appraiser must address that risk.
• Comparable sales
  • Credible, recent, and truly comparable sales are critical. The appraiser should explain why selected comparables are relevant (same artist or maker, date, medium, size, period, quality, condition, provenance, and market context).
• Collections vs. single items
  • For a collection, itemize pieces above $5,000 and provide aggregate analysis where appropriate. The appraiser should avoid bulk “per-pound” or “per-piece” shortcuts unless justified by market reality.

How to vet and document your appraiser

Use this process to reduce audit risk and keep your file tight:

• Verify credentials
  • Ask for the appraiser’s designation(s) and continuing education. If no designation, ask for proof of coursework and a resume showing at least two years of appraising your property type.
• Confirm property-type expertise
  • Request a brief list of recent, similar appraisals (no confidential details) demonstrating experience with your period, maker, artist, or category.
• Confirm independence
  • Put in writing that the appraiser is not the donor, donee, seller, related party, or employee of any party to the transaction, and that the fee is not contingent.
• Nail down deliverables and timing
  • Engagement letter should specify a qualified appraisal meeting IRS content requirements, delivery date (to meet the 60-day window and filing deadline), fee basis, and the appraiser’s willingness to sign Form 8283, Section B.
• Request a method-forward report
  • The appraisal should clearly state the effective date, intended use (income tax/charitable contribution), definition of fair market value, market selection, methodology, and a well-documented analysis with comparables.
• Keep a complete file
  • Save invoices, engagement letter, images, any expert opinions on authenticity, and a copy of the signed Form 8283. For high-value art, keep high-resolution photographs and any catalog raisonnés or literature references cited.

Practical checklist: confirming an IRS-qualified appraiser

• Property-specific expertise:
  • Two or more years appraising this type of property (e.g., fine art paintings, American furniture, Asian ceramics).
  • Relevant appraisal coursework or a recognized appraisal designation.
• Professional practice:
  • Regularly performs paid appraisals; provides a resume/CV.
  • Familiar with USPAP and IRS valuation standards.
• Independence:
  • Not the donor, donee, seller/dealer, or related party; no employment ties.
  • Fee is hourly or flat—not contingent on value or deduction size.
• Documentation:
  • Engagement letter states intended use (charitable contribution), effective date, IRS-qualified appraisal content, and signature on Form 8283, Section B.
  • Appraisal will include method, market selection, comparables, condition, provenance, appraiser qualifications, and appraiser’s identifying number.
• Timing:
  • Appraisal date within 60 days before the donation and received before the tax return is filed (including extensions).
  • For single art items ≥$20,000 or property ≥$500,000, arrange to attach the appraisal to the return as required.

If you can check every box, you’re aligned with IRS expectations.

Short FAQ

Q: Does USPAP compliance automatically make an appraiser “qualified” for the IRS? A: Not automatically. USPAP compliance is a strong indicator of quality and usually covers report content well, but the IRS still requires property-specific education and at least two years’ experience, regular compensated appraisal practice, independence, and a proper declaration. All elements must be met.

Q: Can my dealer or gallery appraise the work I’m donating? A: Generally no. The seller is usually a party to the transaction in which you acquired the property and is a disqualified appraiser for your charitable contribution. Choose an independent appraiser with no stake in the transaction.

Q: Are online-only valuations acceptable? A: For a qualified appraisal, the IRS expects a complete written report signed by a qualified appraiser. Some appraisers can competently perform assignments using digital materials if they can adequately assess condition and market data, but for art and antiques, in-person inspection is often necessary. The key is whether the report meets all IRS requirements, not the delivery channel.

Q: Do I need a qualified appraisal for every donation? A: Only when your noncash charitable contribution exceeds $5,000 (exceptions apply, such as publicly traded securities). For smaller donations, a receipt or simple record may suffice. Always check the value thresholds for attaching the appraisal (e.g., single items of art at $20,000 or property at $500,000+).

Q: Can a museum curator serve as a qualified appraiser? A: Possibly, if they meet all requirements: property-specific education and at least two years of appraisal experience, regular compensated appraisal practice, independence from the donee, and willingness to sign the declaration and Form 8283. Many curators are expert scholars but may not regularly perform compensated appraisals; verify their qualifications against the IRS criteria.

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