COO Report: NACVA Responds to IRS Regulations to Circular 230—First Quarter 2025
Chief Operations Officer’s Report: NACVA Responds to and Testifies at Public Hearing on Proposed IRS Regulations to Circular 230
Brien K. Jones
Chief Operations Officer and Executive Vice President of Business Development
In December 2024, the Department of the Treasury and the Internal Revenue Service (IRS) proposed regulations to:
“… eliminate provisions related to registered tax return preparers, classify the use of certain contingent fee arrangements by practitioners as disreputable conduct, establish new standards for appraisals and the disqualification of appraisers, and update certain provisions as appropriate. The regulations would affect registered tax return preparers, enrolled agents (EAs), enrolled retirement plan agents, enrolled actuaries, Annual Filing Season Program (AFSP) participants, attorneys, certified public accountants (CPAs), appraisers, and other practitioners.” — Federal Register | 12/26/24
“… require appraisals submitted in an administrative proceeding before the IRS to conform to the substance and principles of the Uniform Standards of Professional Appraisal Practice (USPAP) promulgated by the Appraisal Standards Board (ASB) of the Appraisal Foundation or the International Valuation Standards (IVS) promulgated by the International Valuation Standards Council.”— Federal Register | 12/26/24
“Using the substance and principles of the USPAP or IVS appraisal standards as a basis for disqualification would enable the IRS to proactively address inadequate appraisals submitted in administrative proceedings.”— Federal Register | 12/26/24
“… ensure that appraisals submitted in an administrative proceeding generally conform to broadly applicable standards without requiring strict compliance with such standards.”— Federal Register | 12/26/24
To address this urgent matter, NACVA established a task force comprised of members from its Executive Advisory Board (EAB), Standards Board (SDB), and Leadership Initiative Board (LIB) who authored and submitted a response on behalf of the Association, its members, and credential designees. The task force members were:
- Executive Advisory Board — Mallory Ashbrook, Parnell Black, Brien Jones, Mark Kucik
- Standards Board — Greg Clark, Trisch Garthoeffner, Dalton Hopper, Zach Meyers, Carl Steffen
- Leadership Initiatives Board — T.J. Liles-Tims
- Member/Credentialed Designee Appointed — Peter Agrapides
“Establishing this task force in a timely fashion is to ensure that NACVA advocates for its membership and has its voice heard and its professional standards and related resourcesare represented in this process.” Mallory Ashbrook, CPA, CVA, JD, MAFF, Director, Forensic and Dispute Advisory Services with GBQ Partners LLC and member of NACVA’s Executive Advisory Board.
More than 100 responses were submitted to the IRS from individuals and organizations, including: the National Association of State Boards of Accountancy, the International Society of Business Appraisers and NEBB Institute, the AICPA, the State Bar of Texas Tax Section, the Tax Section of the New York State Bar Association, the National Taxpayers Union Foundation, the National Association of Enrolled Agents, the American Bar Association Section of Taxation, the International Valuation Standards Council, the New York State Society of Certified Public Accountants, The Appraisal Foundation, the Pennsylvania Institute of Certified Public Accountants, the IRS Advisory Council, The American Society of Appraisers, the American Society of Tax Problem Solvers, and the National Association of Tax Professionals.
In addition to submitting a response on behalf of NACVA, Task Force Members Trisch Garthoeffner, Dalton Hopper, and T.J. Liles-Tims traveled to Washington, DC to testify in person at the IRS hearing held on Thursday, March 6, 2025.
From left: T.J. Liles-Tims, Trisch Garthoeffner, Dalton Hopper
“Recently, I had the opportunity to testify before the IRS in Washington, DC as a NACVA Standards Board member,” states Dalton Hopper CFE, CVA, ABV, with BMSS Advisors & CPAs in Gadsen, AL. “This experience was a personal and professional privilege and will hopefully be seen as fruitful for the valuation profession, our clients, and the NACVA. With the IRS’s proposed changes of Circular 230, I look forward to the Service’s revisions to the proposed changes and I hope they provide clarity for all valuation professionals, regardless of which of the respectable professional standards he/she chooses to follow.”
"It was an honor to testify before the IRS on behalf of NACVA regarding the proposed regulations on Circular 230,” states Trisch Garthoeffner, ABV, CVA, MAFF, EA, MAcc, with Anchor Business Valuations, LLC in Naples, FL. “This was a vital opportunity to advocate for the valuation profession and ensure that regulatory changes support both practitioners and the public. NACVA remains committed to fostering compliance and excellence in the field, and I was proud to contribute to this important dialogue."
NACVA HQ will keep abreast of developments and report news to the membership at www.NACVA.com.
What are your thoughts on NACVA’s activity on this urgent matter? We welcome your input.
