“We acknowledge…that the Statute does not define ‘more likely than not’ and that forthcoming regulations will provide further guidance on this standard,” said Lari Masten, current chair of NACVA’s Executive Advisory Board, who testified before the same IRS panel. NACVA suggests the IRS develop, with the aid and input of all four credentialing organizations, a “quality assessment tool or checklist,” to measure the “more likely than not” standard, and a binding mediation or peer review board, to review the subject appraisal. In five additional short statements, NACVA recommends the IRS:
1) Give an authoring appraiser reasonable notice when it’s examining a related tax return;
2) Assess no penalties when a taxpayer settlement results in an adjusted value;
3) Revise Letter 4477 so that an examiner “MUST” submit referrals to a field engineer for assistance or consultation;
4) Allow the appraiser sufficient notice and time to prepare for a Letter 4477 meeting; and,
5) Make its general 6695A penalty process more public, instead of keeping the appraisal community “in the dark.”
The complete NACVA statement is also now available among our free downloads.