Date of Death Appraisals in San Diego: Commercial Property, Groves and Farms in Estates and Trusts

San Diego families hold all kinds of real estate in trusts: an older apartment building in North Park or Chula Vista, a small industrial building in Kearny Mesa or Escondido, a neighborhood center in El Cajon, an avocado grove in Fallbrook or Valley Center, a nursery in Oceanside or San Marcos. When the owner dies, the first number the trustee, the executor and the CPA all need is what each property was worth on the date of death. Our statewide guide to date-of-death appraisals covers the basics. This page covers what is different when the property is in San Diego County.

When does a San Diego estate or trust need a date-of-death appraisal?

Most of the time when the property is commercial, agricultural or income-producing. Common reasons:

• Stepped-up basis. Under Internal Revenue Code Section 1014(a), property acquired from a decedent generally takes a basis equal to its fair market value at the date of death. Section 1014(b)(6) also covers the surviving spouse’s half of California community property, if at least half of the community interest was includible in the decedent’s gross estate. When the property is later sold, the CPA needs a supported number.
• Estate tax returns. For larger estates, the value of each property goes on the return. Under Section 2032, the executor can elect to value the estate as of six months after death instead, but only if the election lowers both the gross estate and the tax. That can mean two values for the same property.
• Trust administration. A successor trustee dividing or selling property needs values to treat beneficiaries fairly and to report to them. See trust administration appraisals.
• Equalizing shares. One child keeps the grove, another takes the apartment building and a third takes cash. A value for every property, on the same date, is what makes that split fair.
• Prop 19 and property tax. Reassessment, the family farm exclusion and any appeal of the new value all turn on what the property was worth on the date of death (see below).
• Disputes. Heirs, trustees and creditors sometimes disagree about value. An independent, well-supported report keeps the conversation on the evidence.

General information, not legal or tax advice. Your attorney or CPA decides which values you need.

Where are San Diego probate cases filed?

San Diego Superior Court’s local rules (Division IV, Rule 4.1.2) say the East, North and South County Divisions are included in the Central Division for all probate cases. In practice, that means probate filings from Oceanside to Chula Vista go to the Central Courthouse at 1100 Union Street, San Diego, with a drop-box at the North County courthouse at 325 S. Melrose Drive in Vista. The local rules also make e-filing mandatory for attorneys and represented parties, with limited exceptions.

In a formal probate, the personal representative must file an inventory and appraisal within four months after letters are first issued, unless the court allows more time (Probate Code Section 8800). Under Section 8902, the court-appointed probate referee appraises the inventory property the personal representative does not. That is the court’s inventory value, and it serves a different purpose than a private narrative appraisal. We do not act as a probate referee. We provide independent appraisals to trustees, executors, heirs and their attorneys and CPAs.

Many San Diego estates never see a courtroom because the property was held in a living trust. Then there is no referee, and the successor trustee needs values on their own.

Does each grove or farm parcel need its own value under Prop 19?

Often, yes, and this is where San Diego estates differ from most urban counties. The county’s agriculture is dominated by nursery crops, with avocados and other groves in North County, and many of those farms are made up of several legal parcels.

The State Board of Equalization explains that for transfers on or after February 16, 2021, Prop 19 limits the parent-child exclusion to a family home or family farm, with a value limit, and eliminates it for other real property. For farms, Revenue and Taxation Code Section 63.2 says the exclusion applies separately to each legal parcel that makes up a family farm, and each parcel is treated as its own family farm (except a parcel containing the family home). A family farm means real property under cultivation, used for pasture or grazing, or used to produce an agricultural commodity. The value limit is measured against each parcel’s fair market value at the transfer, so a grove spread over three parcels may need three values, each as of the date of death. See farm and ranch appraisals with several parcels.

An inherited apartment building, retail center or industrial building generally gets a new base year value from the San Diego County Assessor. Under Revenue and Taxation Code Section 480, the change in ownership statement for a death (BOE-502-D) is due within 150 days after the date of death, or, if the estate is probated, when the inventory and appraisal is filed. If the decedent owned property in other counties too, Probate Code Section 8800 requires a certification that the statement was filed in each county. If the new value looks too high, a supported date-of-death appraisal is the evidence for an appeal. For 2026, the State Board of Equalization lists November 30, 2026 as the end of San Diego County’s regular assessment appeal filing period. See property tax appeal appraisals.

General information, not legal or tax advice. Confirm how Prop 19 applies, and your deadlines, with your attorney, your CPA or the Assessment Appeals Board.

What San Diego issues change a value as of the date of death?

A date-of-death appraisal has to read the property as it was on that date. In San Diego County, these come up again and again:

• Water service for groves and farms. The Fallbrook Public Utility District left the San Diego County Water Authority and began buying wholesale water from Eastern Municipal Water District on January 1, 2024, and the Rainbow Municipal Water District detachment was final November 1, 2024. For an agricultural property in those districts, a date of death before or after the switch can mean a different water cost picture, and water cost drives grove economics.
• City of San Diego tenant protections. The Residential Tenant Protections Ordinance, San Diego Municipal Code Sections 98.0701 through 98.0709, took effect June 24, 2023. It limits when a landlord can end a tenancy and adds notice rules for no-fault terminations. It does not cap rents; most rent increase limits come from state law in Civil Code Section 1947.12. For an older apartment building, the rents, leases and rules in place on the date of death shape the income and the value.
• The coast. Property from Oceanside to Imperial Beach can sit inside the California Coastal Zone, where development is reviewed under the Coastal Act and each city’s local coastal program. What an owner could build, rebuild or convert on the date of death is part of highest and best use.
• Wildfire in the backcountry. The Lilac Fire started December 7, 2017 near Bonsall, burned 4,088 acres and destroyed 157 structures. For groves, ranches and property near the wildland edge, the date of death decides whether the appraisal reads a pre-fire or post-fire property and market. See casualty loss appraisals.
• Leases and occupancy on the date. A building that was half vacant on the date of death, or that had a below-market lease with years left, is valued that way, even if it is full today.
• Many markets in one county. San Diego County has 18 incorporated cities, from Oceanside and Carlsbad to Chula Vista, El Cajon and Santee, plus large unincorporated areas. A Kearny Mesa industrial building, a La Jolla retail building and a Valley Center grove do not trade the same way. Comparable sales have to come from the right submarket and the right time.

Can the appraisal be done years after the date of death?

Yes, and it often is. Trusts can take a long time to settle, and sometimes nobody orders an appraisal until a property is about to be sold or a dispute starts. A retrospective appraisal uses the sales, leases and market conditions that were known or knowable as of the date of death. What helps most is anything that shows the property as it was then: photos, the rent roll and leases in place, operating statements, water bills and production records for groves, and records of repairs or permits.

What should you send the appraiser?

• The exact date of death and, if there is one, the probate case number
• The purpose: basis, estate tax return, trust administration, division among heirs, a Prop 19 matter or a dispute
• A list of every property with address, APN and property type, including each legal parcel of a grove or farm, in San Diego County and anywhere else in California
• Rent rolls, leases and operating statements from around the date of death
• For groves and farms: water district, meters and water bills, wells, crop and production records
• Photos and repair or permit records from that time
• Any prior appraisals, purchase contracts, offers or assessor notices
• The attorney or CPA on the estate, and who else will rely on the report

Your appraiser will confirm the exact list on the first call.

How do San Diego trustees, attorneys and CPAs work with PM Appraisal?

You call (805) 990-9700 and talk to the appraiser who will inspect the properties and write the reports. No coordinator and no AMC portal. We pick up the phone, and we are your ears and eyes on the property. Our team is based in San Diego County, and the appraiser inspects the properties in person. Rush commercial appraisals take 5 to 7 business days. Standard timing depends on the property and scope, so call for a timeline on your assignment.

Our opinions are independent. We never take an assignment that requires a predetermined value, and our fees are never tied to the result. If heirs or trustees are on opposite sides, tell us at engagement who the client is and who will rely on the report.

Date-of-death work is one example of what we do. PM Appraisal is a family-owned California appraisal firm with about 40 years of work across the state. We appraise every commercial property type, from office, retail, industrial and multifamily to gas stations, hotels, land, groves, vineyards, medical, care facilities and special-use property, and every kind of commercial appraisal: estate and trust, divorce, retroactive, partition, partner and LLC buyouts, eminent domain, tax appeal, lending and consulting. If the estate holds property in several counties, see multi-property portfolio appraisals and our pages for San Diego, North County San Diego, Orange County, Los Angeles and the Inland Empire. Other county guides: date of death appraisal in Los Angeles and in Orange County. See all services.

This article is general information, not legal or tax advice. Talk to your attorney or CPA about your estate, your trust and your situation.

Keep reading

• Date of death appraisals
• Commercial appraisal in San Diego
• Commercial appraisal in North County San Diego
• Date of death appraisal in California: a guide
• Farm and ranch appraisals in California
• Trust administration appraisals in California
• Estate and trust appraisals

This article is general information, not legal or tax advice. Talk to your attorney or CPA about your situation.