Most valuation disputes begin with a number. A more useful place to start is the process statement: the passages in an IRS Report of Value that describe what the reviewer says was done, under which standards, from which sources, with which qualifications, and subject to which certifications. Those statements are claims. They can be read, listed, and tested against the report itself and the rest of the record.

What the report typically states

Reports differ, but the stated process usually covers some combination of the following:

  • Standards invoked — for example, the Uniform Standards of Professional Appraisal Practice (USPAP), the Internal Revenue Manual, or other requirements the report says it follows.
  • Scope of work — whether the reviewer inspected the property, relied on desk review, or drew on prior reports and public data.
  • Sources — comparable sales, market studies, geological or engineering inputs, feasibility work, and the workfile that supports them.
  • Qualifications and roles — the credentials of the personnel who prepared, reviewed, or signed the report, and the role each played.
  • Certifications and assumptions — the signed statements and the extraordinary assumptions or hypothetical conditions on which the conclusion depends.

Turning statements into a checklist

A disciplined review converts each statement into a question that the record can answer:

  1. Is the statement specific? A report that says it “complies with applicable standards” without naming them leaves nothing to test. A report that names USPAP Standards Rules invites a comparison between what those rules require and what the report shows.
  2. Is the statement supported inside the report? If the report says comparable sales were verified, the verification should be visible. If it says a site visit occurred, the date, participants, and observations should appear.
  3. Is the statement consistent with the rest of the record? Correspondence, engagement letters, prior drafts, and the taxpayer appraisal often describe the same events. Inconsistencies are questions, not conclusions.
  4. Do the qualifications match the work? Where a conclusion depends on geology, mining, solar, or development feasibility, the record should show who performed that analysis and what their credentials were.

Where comparison adds context

Across a research resource of 225+ IRS conservation-easement valuations, certain process characteristics recur—the language used to describe scope, the reliance on desk review versus fieldwork, the way credentials are presented, and the reduction percentages that accompany them. Seeing where a specific report sits among its peers helps counsel prioritize which questions deserve a licensed professional’s attention first.

Verified facts: what the report states about its own process, quoted directly.
Document-based observations: whether the report and the record support each statement.
Interpretation: which gaps are material to the conclusion.
Open questions: items the current record cannot resolve.
Requires a licensed opinion: whether a stated method complied with USPAP, whether a value is correct, and any legal effect—questions for counsel and qualified experts, not for a process review.

Vestal Analytics organizes this review into a structured record so counsel can see, in one place, what the report claims, what supports it, and what remains open.

Publication note: This article distinguishes verified facts, document-based observations, interpretation, open questions, and matters requiring a licensed professional opinion. It is educational, does not disclose client-confidential information, and is not legal, tax, accounting, appraisal, geological, engineering, or investment advice. Professional boundaries.