Stepped-up-basis appraisal in Wittmann is fundamentally a historical fair-market-value assignment for inherited real estate. Road quality, drainage, legal access, and terrain can separate otherwise similar acreage. The appraiser develops the real estate value opinion; the taxpayer and tax professionals determine the applicable basis treatment.
The appraiser's role is to develop a supported fair market value for the applicable historical date. The taxpayer, CPA, attorney, or other adviser determines how that value is used for basis and tax reporting. For Wittmann, the appraisal should consider wash conditions only when it changes the subject's competitive position.
For basis-support valuation, road quality, drainage, legal access, and terrain can separate otherwise similar acreage. For stepped-up-basis support, the question is whether the feature affected fair market value on the applicable historical date.
The appraisal should support the real estate value on the applicable historical date. It does not calculate capital gains, determine the taxpayer's basis election, or replace advice from a CPA or attorney.
The workfile is stronger when the effective date is paired with records showing the subject's condition, ownership interest, and competitive setting at that time. That evidence helps document the real estate value independently of whatever tax treatment is later applied.
A stepped-up-basis appraisal should document the property and market evidence clearly enough that the historical fair market value can be understood later, even if the property is sold or changed afterward.
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