An engineer inherited his mother’s ranch, sold it for $433,500, and then his tax preparer asked one question he could not answer with paperwork. The only official number in his file was a county assessment that cost him dearly.
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A 61-year-old engineer’s mother died and left him her three-bedroom ranch. No estate tax return was filed, no state inheritance tax was due, and no appraisal was commissioned. He let a cousin live there for a while and listed it later.
The property sold for about $433,500. When his tax preparer asked what the house was worth when his mother died, he had only a rough estimate and a county tax bill listing an assessed value of $290,000.
That assessment is now the most official-looking figure in his records, but it is still well below what the home was actually worth.
Inherited Basis Resets to Date-of-Death Value, and the Heir Has to Prove It
Under 26 U.S.C. § 1014(a)(1), an heir’s basis is “the fair market value of the property at the date of the decedent’s death.” Treasury defines that value in 26 CFR 20.2031-1(b) as “the price at which the property would change hands between a willing buyer and a willing seller.”
Under 26 CFR 1.1014-3(a), the value on an IRS estate return counts as fair market value. When no return is required, the value assessed for state inheritance tax counts instead. Most families have neither. Only 7,195 IRS estate returns were filed in 2024.
That leaves the heir carrying the proof problem. Under 26 CFR 1.6001-1(a), taxpayers must keep records enough to support the amounts on their returns. Basis is one of those amounts. If an examiner asks for evidence and the heir has none, the examiner can select a number and the heir must rebut it.
A Sale Within a Year Doubles as the Appraisal
An arm’s-length sale to an unrelated buyer shortly after death closely matches the willing-buyer, willing-seller standard in the regulation. Within roughly a year, the market usually has not changed enough to raise serious doubt, so examiners often accept the closing price as the date-of-death value. The one-year point is a practical rule of thumb. The Code sets the standard for value and leaves the proof to the taxpayer.
Congress uses the same idea in the alternate valuation rule. Under 26 U.S.C. § 2032(a)(1), property sold within six months of death is valued at its sale price. Selling early has another benefit: under 26 U.S.C. § 1223(9), inherited property is treated as held for more than one year, so any gain receives long-term tax rates.
Three Years of Market Drift Erases the Evidence
A later sale price tells little about what the property was worth at death. The Case-Shiller National Home Price Index rose from 310.713 to 336.741 over that span, an increase of about 8.4%. It also moved up and down along the way, including a decline from 331.565 to 326.764. Add renovations or wear from tenants, and the eventual sale price becomes weak evidence of value at death.
Run the Numbers on the Ranch
Assume the ranch was worth $400,000 at death. If it followed the national index, it would be worth about $433,507 later. Assume he files jointly and the gain lands in the 15% bracket under 26 U.S.C. § 1(h)(1)(C). These figures exclude selling costs and state tax.
- With a retrospective appraisal at $400,000: the gain is $33,500, and the federal tax is $5,025.
- With no appraisal, if the examiner starts from the $290,000 assessment: the gain is $143,500, and the federal tax is $21,525.
The missing paperwork costs $16,500. The regulation helps him in theory: 26 CFR 20.2031-1(b) does not allow a local assessed value unless it reflects what the property would bring on the open market. But proving that point requires evidence, and that evidence is an appraisal.
Selling in Year One Brings the Gain to Zero
If he had sold the ranch soon after death for $400,000 to a stranger, the sale price would have become the basis, the gain would have been zero, and the closing statement would have served as the appraisal. The file would have been settled before the market had time to move.
Heirs who want to keep the property still have an option: a licensed appraiser can prepare a retrospective appraisal valued as of the date of death, even years later. It costs far less than the $16,500 it protects, and it fits into the broader cleanup every estate eventually needs (we put the full checklist, beneficiary forms and titling included, in a free report: Die With a Plan).
Five Documents That Lock In the Basis
- Get an appraisal tied to the date of death within the first few months, even if no estate return is required. If you are late, ask for a retrospective valuation.
- If a sale happens within a year, keep the closing disclosure, the listing history and proof that the buyer is unrelated.
- Check with the executor on whether a Form 706 was filed. If it was, the Schedule A of Form 8971 sets your starting basis, according to IRS Publication 551.
- Save printouts of comparable sales from the three months around the date of death.
- Keep receipts for improvements made after you inherit. They add to your basis.
A CPA can confirm how these rules apply to a specific sale.
For this ranch, $16,500 is the price of an appraisal nobody ordered. An heir who sells within a year avoids that problem, and one who keeps the house can avoid it by ordering the appraisal now.
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