Appraiser Suggests Changes to Requirements Under Guidance on Valuing Charitable Contributions

To Whom it May Concern:

In regard to changes in appraisal standards and qualified appraisers, I am generally in agreement with and welcome those changes which set a high standard for appraisals made in conjunction with charitable contributions.

I am a certified general real estate appraiser in both New Hampshire and Vermont. I have been appraising conservation easements for 20 years and have conducted between 300 and 400 such appraisals. Ten of my clients have been audited over the years, and the appraisals reviewed by IRS reviewers as part of the process. In all ten cases, my appraisals passed IRS scrutiny. I have conducted numerous appraisals of conservation easements for the Department of Agriculture, and my appraisals have been reviewed by the Justice Department and passed such scrutiny. I have taken numerous appraisal courses over the years, including the available courses on conservation easements. I have taught seminars on appraising conservation easement. I have never had a complaint at any level about the quality, accuracy, and integrity of my work.

I would not be a "qualified appraiser" under your new guidelines.

As with many appraisers nation-wide, I dropped pursuit of an appraisal designation in 1992 when state licensing went into effect. Since that time, I have had no need for an appraisal designation from a recognized professional organization for any of the work I have done for private clients, the courts, or state and federal agencies.

Many of the best, most honest, and thorough appraisers in this region do not have an appraisal designation from a recognized professional organization. Perhaps less than 20% of the top appraisers in Vermont have such a designation. Implementation of the requirement for "appraisal designation from a recognized professional organization" will affect the livelihood of many excellent appraisers, and leave the area with a severe shortage of appraisers able to perform appraisals of charitable contributions.

Although I do not have an appraisal designation, I believe I have the work experience and educational background to perform qualified appraisals. The appraisal of charitable contributions constitutes about 50-60% of my livelihood.

I urge that you amend your regulations to either: