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Internal Revenue Service (IRS) Sends Formal Written Response to ASA Letter Seeking Clarification on “Similar Items”

Jan 30, 2020

Reinforces Previous Informal Response Given to ASA by IRS

On January 16, 2020, the IRS wrote a letter responding to a June 12, 2019 letter ASA had sent seeking clarification of IRS’s position on how to categorize and aggregate “similar items” for purposes of completing Form 8283 regarding appraisals in connection with noncash charitable contributions. In its letter, the IRS made two key points that align both with an informal response that IRS had provided, as well as IRS’s historical interpretations:
  • That while dissimilar items must be handled in separate Form 8283’s, the appraisal of each dissimilar item may be addressed in one appraisal report with separate chapters or sections for each item; and,
  • That when the Fair Market Value of two or more items are less than $5,000 but are similar in nature, and the aggregate value of the items will exceed $5,000, an appraisal must be completed as well as a Form 8283 (or multiple 8283s, where more than one donee is involved).
ASA appreciates IRS responding substantively and timely to our inquiry and clarifying confusion that had occurred in recent months. To read the full text of the IRS letter to ASA, click here.