Skip to content
Clear Money Guide Calculate fees
Menu

The Appraisal Rule That Voids Deductions

Updated July 28, 2026. Quick answer: Property gifts above the statutory threshold require a qualified appraisal and a donee-signed Form 8283 under IRC §170(f)(11). The failure mode is unusually harsh: the deduction can be denied entirely on a substantiation defect, even where the valuation itself was correct. And splitting a collection across several charities does not escape it, because similar items are aggregated.

The aggregation trap

The requirement applies to similar items of property in the aggregate, not to each individual gift. Donating a set of items to five different charities in the same year does not produce five small gifts below the threshold — it produces one aggregate gift that is tested as a whole.

GiftSubstantiation
CashBank record or written acknowledgement
Publicly traded securitiesNo appraisal — value is observable
Real property, art, closely held stock above the thresholdQualified appraisal and donee-signed Form 8283

The consequence is disproportionate to the paperwork. Substantiation failures have produced complete disallowance of otherwise legitimate gifts. This is not an area to handle after the fact — the appraisal and the signature have to exist by the time the return is filed.

Two rules that catch property donors

Partial interests. Giving a charity the use of a building, or any slice short of your entire interest in the property, generally produces no deduction at all.

Unrelated use. Tangible personal property — artwork most obviously — given to a charity that will not use it in its exempt function is reduced to basis under §170(e)(1)(B). Donating a painting to a museum that will hang it and to a charity that will auction it produce different deductions for the same painting.

A stock gift also has a completion-date trap worth knowing before December: a gift routed through the issuing corporation for re-registration is not complete until the transfer is recorded, which can push a year-end gift into January.

No dollar figures appear here, and that is deliberate. The QCD annual cap is inflation-indexed and the figure printed in IRC §408(d)(8)(A) is the original un-indexed amount, which the statute will keep reciting forever. AGI ceilings are percentages, not amounts. Take current dollar limits from the IRS for the year in question, never from an article.

Sources

IRC §170(b)(1)(A), (b)(1)(C), (b)(1)(D), (b)(1)(G), (b)(1)(I) and (d)(1); §170(e)(1) and (e)(5); §170(f)(11) (appraisal); §68 as amended; §408(d)(8) (qualified charitable distributions); §4966(d)(2) (donor-advised funds); §664(d)(1) and (d)(2) (charitable remainder trusts). Amendments from P.L. 119-21. IRS Publication 505 (2026) for the 0.5% floor’s first application year. All read July 2026.

This states what the cited authority says. It is not tax advice, and retirement-plan design turns on facts about your business and your other entities that no page can see. Every dollar limit referenced here is indexed and changes annually.

Related