The IRS is switching its auditing focus from FLPs to fractional interest discounts and discounts in general according to the IRS update presented at NACVA's Consultants Conference in San Francisco last week. The Service is also increasing and improving its internal resources under §6701(a) (concerning appraiser liability); they’ve now credentialed 40% of their internal appraisers, and “have more work than we know what to do with.”

“Like any government agency, we’ve been slow to get going,” the IRS rep admitted. Currently, they only have 20 appraiser liability cases nationwide—and half of these concern conservation easements. “But the train has left the station, and is building up steam.”