Reference Guide · California Appraisal Types
Four Different Values
for One Inherited House:
Which Appraisal Do You Need?
By William B. Plevy, California Attorney & Real Estate Broker · DRE #01956776 · Published July 2026
Reference guide only. Appraisal requirements depend on the specific transaction, court, or purpose. This is not legal, tax, or appraisal advice. Consult a qualified California attorney, tax advisor, or licensed appraiser for guidance on your specific situation.
One inherited California home. Multiple different values, all potentially "correct" for their intended purpose. Understanding which appraisal you actually need, when, and why, prevents delays and unnecessary expense.
Families are often surprised to learn that an inherited California home may need several different valuations for different purposes during administration. The date-of-death value for federal tax basis. A probate referee appraisal for court filings. A current market analysis for listing. A buyout valuation for family transactions. Each serves a distinct purpose. Confusing them, or using the wrong one, creates problems.
This guide organizes the four common types of appraisals used with inherited California property, when each is needed, who provides it, and how they interact.
Appraisal 1
Date-of-Death Appraisal
Establishes fair market value on the date the borrower died, used for federal tax basis and California administration.
Purpose:
Federal stepped-up basis (Internal Revenue Code Section 1014); California administration valuations; establishing beneficiary shares.
Who provides:
Licensed California residential appraiser, typically hired by the estate, trust, or heirs.
Timing:
Effective date is the date of death. Report can be prepared later using a retrospective appraisal.
Typical cost:
$400 to $800 for standard residential properties; more for complex or high-value properties.
Format:
Full narrative or form-based appraisal report with comparable sales analysis effective as of date of death.
Required for:
Establishing stepped-up basis when the property will eventually be sold; supporting tax returns; supporting family agreements.
Appraisal 2
Probate Referee Appraisal
Court-appointed valuation used specifically in California probate proceedings.
Purpose:
Establishing property value for the California probate inventory and appraisal (Form DE-160/161).
Who provides:
Court-appointed California probate referee. The referee is randomly assigned by the court, not chosen by the family.
Timing:
During probate administration, typically after appointment of the personal representative.
Typical cost:
0.1% of appraised value with a minimum of $75. On a $1M property, approximately $1,000.
Format:
Simplified valuation attached to the court inventory. Less detailed than a full appraisal report.
Required for:
Any California probate case where the estate holds real property. Not required for trust administration or non-probate transfers.
Appraisal 3
Current Market Analysis (CMA)
Real estate agent's opinion of current market value for listing purposes.
Purpose:
Establishing a competitive listing price when the property will be sold.
Who provides:
Licensed California real estate agent, typically as part of pre-listing consultation.
Timing:
Close to the intended listing date, typically within 30 days.
Typical cost:
Usually free as part of listing agent's proposal. Some agents charge modest fees for standalone CMA services.
Format:
Comparative analysis using recent sales, active listings, and pending sales in the neighborhood.
Required for:
Setting the listing price. Not a substitute for a formal appraisal for tax, legal, or fiduciary purposes.
Appraisal 4
Buyout or Family Transaction Appraisal
Current fair market valuation used when one family member buys out others.
Purpose:
Establishing the price at which one heir purchases the interests of other heirs. Different from date of death because the property may have appreciated or depreciated since.
Who provides:
Licensed California residential appraiser, typically retained jointly by the parties or by the trustee.
Timing:
Close to the intended transaction date, typically within 60 to 90 days.
Typical cost:
$400 to $800 for standard residential properties; more for complex or high-value properties.
Format:
Full appraisal report meeting Uniform Standards of Professional Appraisal Practice (USPAP).
Required for:
Sibling buyouts; establishing fair price when one heir keeps the property while others receive cash.
How the Four Interact
Understanding when each appraisal is needed together, versus when only one applies, prevents unnecessary expense and delay.
| Situation |
Appraisals Typically Needed |
| Trust sale, sole beneficiary, sold within 60 days of death |
CMA for listing (also serves as approximate date-of-death value) |
| Trust sale, sole beneficiary, sold 6+ months after death |
Date-of-death appraisal + CMA for listing |
| Probate sale, real property inventory required |
Probate referee appraisal + CMA for listing |
| Sibling buyout without sale |
Date-of-death appraisal + buyout appraisal |
| Occupying heir claims Prop 19, then later sells |
Date-of-death appraisal + CMA at sale + potentially reassessment appraisal |
| Property held as rental after inheritance |
Date-of-death appraisal + rental market analysis + subsequent revaluations |
The Cost of Skipping the Date-of-Death Appraisal
The most common expensive mistake: not getting a proper date-of-death appraisal because the property was sold quickly. If the sale price is used as the effective date-of-death value, that works only if the sale was close enough in time to death that market conditions did not change materially. For sales more than a few months after death, IRS or beneficiary questions about the actual date-of-death value can arise years later. A modest expense (approximately $500) at the time of death prevents complicated retrospective valuations later.
Common Questions
Can a date-of-death appraisal be used to set a sibling buyout price?
Usually not directly, unless the buyout is happening shortly after death. Buyout prices should typically reflect current fair market value, which may be higher or lower than date-of-death value depending on how much time has passed and how the market has moved. Using date-of-death value for a buyout years after death may unfairly advantage or disadvantage one party depending on which way the market moved.
How old can an appraisal be before it should be updated?
For active transactions, most professionals treat appraisals as valid for 60 to 120 days depending on market conditions. In volatile markets, updates may be needed sooner. In stable markets, appraisals may remain useful for longer. Trustees and executors making decisions based on old appraisals should update them before major transactions.
Is a Realtor's CMA sufficient for fiduciary purposes?
Generally no. A CMA is a market opinion, not an appraisal. Fiduciary decisions affecting beneficiary distributions, tax filings, or court-supervised transactions typically require a formal appraisal from a licensed appraiser. Using a CMA where an appraisal is needed can expose the trustee or executor to later challenge.
Who selects and pays for the appraiser?
For date-of-death and buyout appraisals, the trustee or executor typically selects and the estate or trust pays. For probate referee appraisals, the court assigns the referee. For CMAs, the listing agent typically provides one at no charge as part of their proposal.
What if two beneficiaries obtain conflicting appraisals?
This happens most often in family disputes over buyouts. Common approaches: engage a mutually agreed independent appraiser; average two independent appraisals; commission a third appraisal from a specialist to resolve the difference. In litigation, courts may require expert testimony from appraisers.
Can a retrospective appraisal establish date-of-death value?
Yes. A licensed appraiser can prepare a retrospective appraisal with an effective date in the past (typically the date of death) using historical market data. This is common when the family did not obtain an appraisal at the time and later needs one for tax or administration purposes.
What if the home has materially deteriorated or improved since death?
Appraisals valued as of specific dates reflect the property's condition on that date. If material changes have happened, additional valuation work may be needed to properly account for them. This is particularly important for buyout transactions when the occupying beneficiary has invested in improvements or when the property has deteriorated during administration.
Practical Recommendations
Based on how these appraisals typically interact, here is what I recommend to California families and trustees:
- Get a date-of-death appraisal within 60 days of death. Even if you are not sure yet what the family will do with the property, establishing the date-of-death value is inexpensive and prevents complications later.
- Do not rely on the probate referee appraisal for tax or family purposes. The probate referee valuation is designed for court administration, not for federal tax basis or family transactions.
- Get a CMA at least 30 days before listing. Market conditions change. A stale CMA can lead to mispricing.
- For buyouts, use a recent appraisal, not the date-of-death value. Fair current market value protects both the keeping heir and the exiting heirs.
- Consider engaging one appraiser for multiple purposes. A single professional can provide both a retrospective date-of-death appraisal and a current appraisal for a buyout, often at reduced combined cost.
- Document your valuation decisions. If you are choosing to rely on a specific appraisal type for a specific purpose, document the reasoning to protect against later questions.
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William B. Plevy, California Attorney & Real Estate Broker · DRE #01956776
William is a California attorney and licensed real estate broker who founded Wolf Allies to connect families with specialists in trust, probate, and inherited property sales. Wolf Allies is a real estate referral platform, not a law firm.