4.48.2 Valuation Assistance for Cases Involving Works of Art

Manual Transmittal

October 01, 2012


(1) This transmits revised IRM 4.48.2, Engineering Program, Valuation Assistance for Cases Involving Works of Art.

Material Changes

(1) Revised IRM to reflect new organizational titles resulting from the Appeals 2012 Alignment Project.

(2) Revised IRM to incorporate Interim Guidance, Mandatory Use of the Specialist Referral System (SRS) for Art Appraisal Services (AAS), Control No. AP-08-0612-03.

Effect on Other Documents

This supersedes IRM 4.48.2 dated December 14, 2010, and incorporates Interim Guidance, Mandatory Use of the Specialist Referral System (SRS) for Art Appraisal Services (AAS), Control No. AP-08-0612-03.


Criminal Investigation (CI), Large Business & International (LB&I), Small Business/Self-Employed (SB/SE), Tax Exempt/Government Entities (TE/GE), Wage & Investment (W&I), Chief Counsel

Effective Date


Kirsten Wielobob
Director, Specialty Operations

Art Appraisal Services Overview

  1. Art Appraisal Services (AAS):

    • Provides advice and assistance to the Service, other Government agencies, and taxpayers on valuation questions arising in connection with personal property and works of art,

    • Assists the Office of Chief Counsel and Department of Justice (DOJ) in appraisal reviews for trial or pretrial settlement in cases involving valuation issues, and

    • Manages the Commissioner's Art Advisory Panel.

Art Advisory Panel

  1. The Commissioner maintains an Art Advisory Panel of nationally prominent art museum directors, curators, scholars, art dealers, auction representatives, and appraisers to systematically aid the Service in the review of Service-selected cases involving taxpayer valuations on art objects, principally American and European paintings and sculpture.

  2. AAS provides the staff support and coordination of the Panel's functions.

  3. The Panel members, after reviewing photographs or color transparencies, along with relevant documentation provided by the taxpayers and research by the staff appraisers, make recommendations on the acceptability of the claimed values. If unacceptable, the Panelists make alternate value recommendations. Such recommendations are advisory only; however, after review by AAS, these recommendations become the position of the Service.

  4. Reconsideration of Value Determinations. If agreement cannot be reached with the taxpayer, further assistance may be requested of AAS and the Panel. The taxpayer may request reconsideration of an adjusted claimed value only if they provide additional evidence such as comparable sales data or other relevant facts to support their fair market value opinion. The taxpayer’s request must respond specifically to the report issued by AAS.

  5. Further Assistance. The appraisers will provide assistance to the Operating Divisions, Appeals and Chief Counsel. Upon request, the designated appraiser may participate in taxpayer conferences, may prepare a detailed expert report for use in Tax Court trials, and may testify as an expert witness in support of the report or may assist in procuring outside experts and/or Panelists.

Criteria for Requesting Art Appraisal Services Assistance

  1. IRS employees must refer cases to AAS that involve a taxpayer’s appraisal of a single work of art with a claimed value of $50,000 or more, including paintings, drawings, prints, sculptures, antiques, ceramics, decorative arts, textiles, carpets, silver, rare manuscripts, antiquities, ethnographic art, collectibles, classic automobiles, and historical memorabilia. Subject to the discretion of AAS, the taxpayer’s appraisal may also be submitted for additional review by the Commissioner’s Art Advisory Panel.

  2. AAS appraisers also provide valuation assistance on art work valued at under $50,000 (in special cases), as well as works of art and other collectibles not referred to the Commissioner’s Art Advisory Panel.

  3. Requesters may contact the AAS appraisers by telephone to informally discuss a valuation to determine the type of assistance required and whether a formal written request is needed.

Art Appraisal Services Referral Procedures

  1. When a formal request is appropriate, it must be written and forwarded to AAS via the Specialist Referral System, https://srs.web.irs.gov.

  2. For more information, see:

    • IRM, Art Valuation Requests Overview,

    • IRM, Art Valuation Request Requirements, and

    • Appeals AAS referrals website, http://appeals.web.irs.gov/art/art_referrals.htm.


Form 8256 Procedures

  1. Form 8256, Art Valuation is a feedback loop form that AAS partially completes and includes with its closing memorandum and report, and the referring office completes and returns to AAS upon disposition of the case.


    The referring employee's manager is responsible for ensuring that a copy of the completed Form 8256 is returned to AAS immediately upon disposition of the case.

    1. The AAS appraiser completes Section I of Form 8256 and attaches it to the AAS closing memorandum and report.

    2. The referring office completes Section II of Form 8256 and mails a copy of the updated Form 8256 to:
      Internal Revenue Service/Appeals
      Attn: Director, AAS (AP:SO:ART)
      1111 Constitution Ave, Suite 700
      Washington, DC 20224


      Keep the updated original Form 8256, along with the AAS closing memorandum and report , in the case workpaper file, after indexing it on Examination Workpapers Form 4318 or Estate and Gift Tax Exam planning documents and/or lead sheets and workpapers.

  2. To further enhance the valuation assistance provided by AAS, requesters are encouraged to include comments and supporting documentation that would be beneficial to the viability of this program.

  3. Also see IRM, Receiving Office's Closing Procedures, for additional information.