# Working with reviewers on a cost segregation study Independent review is how errors leave a study before an examiner finds them. What a reviewer reads first, how to prepare a file, and how to answer findings. ## Short answer A reviewer is someone who did not prepare the study and reads it the way an examiner would, before an examiner does. The IRS's Audit Techniques Guide describes what examiners request and what they look at; a reviewer works from the same list, in the same order, with the advantage of being on your side and the discipline of not pretending to be. Good practitioners seek review, prepare their files for it, answer findings in writing and keep the record. This article explains what reviewers read first, how to prepare a file so the review is about substance rather than housekeeping, how to answer findings, and how review works inside NBCSS's own processes. It is general education for practitioners, not tax advice. ## Why review is not optional - **The preparer cannot see their own assumptions.** A land split chosen early becomes invisible by the time the asset list is done. A reviewer sees it fresh. - **The examiner's list is public.** The guide tells examiners to request the study, the workpapers, the construction documents and the preparer's qualifications, and to examine the basis for classifications and costs. A review against that list is a rehearsal. - **Competence includes consultation.** Circular 230 tells practitioners who practice before the IRS that competence may be acquired through consultation; the broader point holds for everyone: review is how one person's competence is checked by another's. - **Clients and advisers rely on it.** A reviewed study carries a second name, and an adviser who knows a reviewer read the file relies on it differently. ## What a reviewer reads, in order | Order | What | Why first | |---|---|---| | 1 | The reconciliation | Whether the study is arithmetically closed and what share rests on estimates | | 2 | The land split and its evidence | Whether the depreciable pool was established | | 3 | The asset list and the legal analysis | Whether each class has a reason, and where judgement was exercised | | 4 | A sample of costs against take-offs and sources | Whether unit costs are for the right place and date and quantities trace to drawings or the site | | 5 | The document index and site record | Whether the evidence claimed exists and what was requested but not received | | 6 | The dates | Whether acquisition and placed-in-service dates are supported | | 7 | The methodology and limitations sections | Whether the report describes what was actually done | | 8 | The engagement letter | Whether the scope delivered matches the scope agreed | A reviewer who starts with the narrative and never reaches the reconciliation has read the wrong end of the report. ## Preparing a file for review The reviewer's time should go to substance. Before sending a file: 1. **Close the arithmetic.** The reconciliation ties, or the difference is explained on the page. 2. **Mark actual and estimated.** Every cost is labelled with its source. 3. **Index everything.** Documents received, documents requested and not received, the site record and photographs keyed to the asset list. 4. **Write the reasons.** Every classification has a paragraph: function, authority, conclusion. Judgement calls are flagged. 5. **State the dates and their evidence.** 6. **Attach the engagement letter and the draft limitations section.** 7. **List your own doubts.** A short note of the items you are least sure of directs the reviewer to where the risk is. Reviewers respect it and examiners never see it. A file prepared this way gets a review about classification judgement and cost support. A file that is not gets a review about missing pages. ## Answering findings Findings arrive as a list: an item, what the reviewer saw, what they expected, and sometimes a suggested fix. Answer each one in writing, in one of three ways. - **Accepted.** Say what changed, re-run the reconciliation, and note the revision in the report's version history. - **Accepted in part.** Explain what changed and what did not, and why. - **Not accepted.** Give the reasoning and the authority. Reasonable disagreement about a classification is normal; the reviewer's finding and the preparer's response both go in the file, and the engagement lead decides what the report says. What is not an answer: silence, a global "addressed," or a change made without re-reconciling. The findings log, with responses, is part of the workpapers and is what shows a later reader that the review happened. ## Getting review as a solo practitioner Solo practitioners lose the reviewer role first and need to replace it deliberately. - A reciprocal arrangement with another practitioner, each reviewing the other's files under a confidentiality agreement and with client permission for redacted material. - A reviewer engaged for the purpose on larger or unusual engagements. - A professional body's peer review, where one exists. - At minimum, a structured self-review with a delay: set the file aside for days and then read it in the reviewer's order, starting with the reconciliation. It is not independent, but it catches more than reading it warm. ## How review works at NBCSS NBCSS applies the same separation to its own processes that it recommends for practice. Reviewers, examiners and the decision-maker hold recorded roles. No one reviews their own work or decides their own appeal. Assessment results are released by a technical reviewer who is not the appeal reviewer, and appeals are rescored reproducibly from the locked submission. Members' sample reports are reviewed by people with recorded roles during admission. The point of describing this here is not to advertise it but to show what "independent" means when it is built into a system: a record of who did what, and a rule that the doer and the checker are different people. ## What a good finding looks like A useful finding names the item, states what the reviewer saw, states what the reviewer expected and why, and, where possible, points to the evidence or authority that would resolve it. "Land split unsupported" is a note; "Land allocated at 15 percent with no source; the appraisal in the file values the site at 24 percent of the price and the assessor ratio is 22 percent; explain the departure or adopt the appraisal" is a finding. The second can be answered; the first starts an argument. Reviewers who write findings this way get better files back, and preparers who answer them this way build a workpaper record that reads as a conversation between two competent people rather than a checklist. Findings should also be proportionate. A file with a broken reconciliation does not need thirty comments on wording; it needs one finding that says stop and fix the arithmetic, and a second review afterward. Ordering findings by consequence, with the reconciliation, the land split and unsupported classifications first, tells the preparer where to start. ## Signs that review has become a formality - Findings are always zero. - The reviewer is the preparer's junior, or reports to them. - Findings are answered "addressed" without a re-reconciliation. - The reviewer receives the report but not the workpapers. - Review happens after the report has gone to the client. Any of these means the review is not doing its job, whatever the checklist says. ## What people ask on Reddit and other forums The searches that lead people to these threads are usually phrased "cost segregation quality review", "peer review cost segregation", "second review of a study". Practitioners on r/Accounting ask, and "cost segregation reddit" searches surface, how a solo practice gets a second set of eyes. From the sources below: **"I'm solo. Who reviews my work?"** A reciprocal arrangement with another practitioner, a reviewer engaged for the purpose, a professional body's review, or at minimum a delayed structured self-review starting with the reconciliation. **"Does my client's CPA count as the reviewer?"** The adviser reviews for use on the return, a different purpose. Independent technical review before the report issues is still needed. **"What does a reviewer read first?"** The reconciliation, the land split, the asset list and its legal analysis, then samples of costs against take-offs and sources. **"What if we disagree?"** Both positions go in the file with reasons and authority; the engagement lead decides what the report says. ## Questions people also ask ### Who should review a cost segregation study? Someone who did not prepare it and who has the construction, cost and legal competence to test it: a senior practitioner in the firm, a peer in another firm, or an engaged reviewer. ### Does the client's tax adviser count as the reviewer? The adviser reviews the study for use on the return, which is a different review with a different purpose. Independent technical review before the report issues is still needed. ### How long should review take? Enough to read the reconciliation, the land split and the asset list fully, sample costs and classifications against the file, and write findings. A review measured in minutes has read the summary. ### Should the reviewer's name appear in the report? The IRS guide expects the preparer to be identified; naming the reviewer as well is good practice and tells the reader that a second person stands behind the file. ### What if the reviewer and I disagree? Both positions go in the file with reasons and authority, and the engagement lead decides what the report says. Disagreement recorded is evidence of a real review. ## Sources - https://www.irs.gov/pub/irs-pdf/p5653.pdf — IRS Publication 5653, Cost Segregation Audit Techniques Guide (Rev. 2-2025): Chapter 4, principal elements; Chapter 5, review and examination. - https://www.irs.gov/pub/irs-pdf/pcir230.pdf — Treasury Department Circular No. 230: §10.22, §10.35. - https://nbcss.org/standards — NBCSS standards and governance: attempts, retakes and appeals; who decides. ## Related reading - [How reconciliation reveals errors](/articles/how-reconciliation-reveals-errors) - [Who does what: preparer roles in a cost segregation study](/articles/preparer-roles-in-a-cost-segregation-study) - [How to read a cost segregation report's limitations](/articles/reading-report-limitations) - [Maintaining professional competence](/articles/maintaining-professional-competence) - [Responsible AI use in cost segregation work](/articles/responsible-ai-use-in-cost-segregation) - [Standards and governance](/standards) --- Canonical: https://nbcss.org/articles/working-with-reviewers Published: 2026-09-25 · Last content change: 2026-09-25 Not professional advice: general educational information from the National Board of Cost Segregation Specialist (NBCSS); not accounting, tax, legal, financial, investment or engineering advice. 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