Regulation reference · IRS Publication 5653

The IRS Cost Segregation Audit Techniques Guide a plain-English companion.

The Cost Segregation Audit Techniques Guide (ATG) is the guide the IRS gives its examiners for reviewing cost segregation studies. It is published as IRS Publication 5653. It is not law, and the IRS says it has set no required standard for studies, but it is the clearest statement of what an examiner looks for.

The official guide

IRS Publication 5653, Cost Segregation Audit Techniques Guide (Rev. 2-2025). When you need the exact wording, use the IRS document.

Download Publication 5653 (PDF, irs.gov)

What this page adds: a map of the guide's eight chapters, the 13 elements of a quality study in plain English with a question to ask about each, and the first things an examiner checks.

What the guide says the IRS requires

Less than most people assume. In its own words, the IRS "has not established any requirements or standards for the preparation of cost segregation studies" (Chapter 3). What the guide does insist on is substantiation: the classification of property is "factually intensive and must be supported by corroborating evidence," and actual costs are more reliable than estimates. Where estimates are the only option, the methodology and the source of the cost data should be clearly documented.

Every study, whatever its length or method, should do three things (Chapter 4):

  • Classify assets into property classes: land, land improvements, building, equipment, and furniture and fixtures.
  • Explain the rationale, with legal citations, for classifying each asset as §1245 or §1250 property.
  • Substantiate the cost basis of each asset and reconcile total allocated costs to total actual costs.

How the guide is organized

ChapterWhat it covers
1. IntroductionPurpose of the guide and background on cost segregation.
2. Legal frameworkThe history of depreciation, §1245 vs §1250 property, the tests courts use to tell them apart, and the Hospital Corporation of America case.
3. Cost segregation approachesThe six common approaches and what the IRS requires of them (nothing prescribed).
4. Principal elements of a quality study and reportThe 13 elements of a quality study and the nine parts of a quality report.
5. Review and examination of a studyHow an examiner reads a study, verifies basis and decides what to look at.
6. Special topicsUniform capitalization, accounting method changes, depreciation basics, case-law tables, the inherently permanent standard, construction process, sample information document requests, §179, §179D and bonus depreciation.
7. Industry-specific guidanceAsset classification matrices for retail, restaurants, pharmaceutical and biotech, casinos, auto dealerships, auto manufacturing and residential rental property.
8. Issue-specific guidanceElectrical distribution systems and stand-alone open-air parking structures.

For an owner, the most useful parts are Chapter 4 (what a quality study contains) and the Chapter 7 matrix for your property type.

The six study approaches

Chapter 3 describes the approaches examiners commonly see. It does not require any of them.

  • Detailed engineering from actual cost records. Uses the actual construction cost records; generally the most methodical and accurate.
  • Detailed engineering cost estimate. Estimates component costs when actual records are not available.
  • Survey or letter. Relies on a contractor's or architect's letter or survey of costs.
  • Residual estimation. Estimates certain components and assigns the remainder to the building.
  • Sampling or modeling. Applies the results of studied properties to similar ones.
  • "Rule of thumb". A fixed percentage from industry averages; the guide tells examiners to view it with caution.

The 13 principal elements of a quality study

The guide calls a study that is "both accurate and well-documented" a quality study, and lists 13 elements it contains (Chapter 4). They describe quality, not a pass/fail test, and they are a good checklist when you compare providers.

#ElementWhat the guide looks forQuestion to ask
1Preparation by an individual with expertise and experienceKnowledge of both construction and the tax law. The guide notes there are no prescribed qualifications, and says a quality study identifies the preparer and their credentials.Who prepared the study, and does the report say so?
2Detailed description of the methodologyThe study describes the method used and the steps taken to classify assets and determine costs.Does the report explain, step by step, how the numbers were produced?
3Use of appropriate documentationThe best available documents. For a purchased building: the purchase agreement first, how the price was split between land, building and other assets (land determined first), deterioration and obsolescence, appraisals, and a site visit with photographs.Which of my documents did the study use, and where does the land value come from?
4Interviews conducted with appropriate partiesInterviews with contractors, owners and property managers about how the property is used, documented in the study.Did anyone ask me how the property is actually used?
5Use of a common nomenclaturePlain terms consistent with the project documents. The guide warns against "creative" names that disguise an asset, such as building water piping called "process piping."Are the components named in plain language I recognize?
6Use of a standard numbering systemA standard system such as the CSI MasterFormat divisions, consistent with bid documents and pay requests.Is each line item organized by a recognized building-system code?
7Explanation of the legal analysisLegal citations supporting each §1245 classification, including where court decisions conflict, reconciled to the property's facts.Does each reclassified item cite its asset class or authority?
8Determination of unit costs and engineering "take-off"Documented unit costs. When actual costs are not available they are estimated, and the guide says estimates are "always reconciled to an acquisition price or a total project cost."Where do the component costs come from, and how were they estimated?
9Organization of assets into lists or groupsAssets listed by recovery period, tying to the taxpayer's fixed asset ledger.Can my CPA enter the schedule straight into the depreciation software?
10Reconciliation of total allocated costs to total actual costsOne estimating technique applied to every item, total allocated costs reconciled to total actual costs, and separately bought furniture and equipment listed separately so nothing is counted twice.Does the schedule add up to my depreciable basis, and is anything counted twice?
11Explanation of the treatment of indirect costsAll direct and indirect costs listed, with indirect costs (permits, general conditions, overhead and profit) explained and allocated to the assets they relate to.How were closing or indirect costs spread across the components?
12Identification and listing of §1245 propertyThe §1245 property listed with amounts, showing what was reclassified from §1250.Is there a clear list of the personal property and its cost?
13Consideration of related aspectsRelated issues such as uniform capitalization under §263A, a change in accounting method (Form 3115 for prior years), and sampling techniques for large portfolios.If the property was placed in service in an earlier year, does the study address the catch-up?

What a quality report contains

The guide separates the study (the work) from the report (what you receive). A quality report has nine parts: a summary letter or executive summary naming the preparer, date, taxpayer and property; a narrative explaining the property, the rationale and the supporting law; a schedule of assets that ties to your depreciation records; a schedule of direct and indirect costs; a schedule of property units and costs; the engineering procedures used; a statement of assumptions and limiting conditions; a certification; and exhibits such as photographs and drawings.

What an examiner checks first

Chapter 5 walks an examiner through the review. The first three steps:

  1. Read the report. Background on the property, the method, the assets and their recovery periods, and the authority for each classification.
  2. Verify the cost basis and reconcile depreciation records. The study should tie to the depreciation schedules on the return, and to prior-year schedules for a look-back study. Examiners check whether furniture and equipment listed elsewhere were counted again.
  3. Decide what to look at. A risk analysis of the property unit descriptions, the reclassified amounts and the method, to set the scope of the exam.

Chapter 6 includes the document requests an examiner may send, covering who prepared the study, the properties, drawings, the study itself and its computations.

Residential rental property

Chapter 7 includes a matrix for residential rental property (Exhibit A) with the recommended classification and recovery period for common rental assets: most §1245 property in a rental (such as appliances and carpeting) under asset class 57.0, five years; land improvements such as fencing, sidewalks and parking areas under asset class 00.3, 15 years; and the building itself at 27.5 years. The guide tells examiners that when a return is consistent with the matrix, they should not adjust the classification or recovery period. For a rental owner it is the single most useful table in the guide.

See also IRS Publication 946, explained for recovery periods, and the 15-year life of land improvements.

Frequently asked

The Audit Techniques Guide, in detail.

What is the IRS Cost Segregation Audit Techniques Guide?
It is the guide the IRS gives its examiners for reviewing cost segregation studies, published as IRS Publication 5653. The current edition is Rev. 2-2025. It explains the legal background, the common study approaches, the 13 principal elements of a quality study, how examiners review a study, and asset classification matrices for several industries, including residential rental property.
Is the Audit Techniques Guide law? Does a study have to follow it?
No. An Audit Techniques Guide is guidance written for IRS examiners; it is not a statute or regulation. The guide itself says the IRS has not established any requirements or standards for preparing cost segregation studies. What it gives you is a clear picture of what an examiner will look for, which is why most quality studies are organized around it.
What are the 13 principal elements of a quality cost segregation study?
Chapter 4 lists them as: preparation by an individual with expertise and experience; a detailed description of the methodology; use of appropriate documentation; interviews with appropriate parties; common nomenclature; a standard numbering system; an explanation of the legal analysis; determination of unit costs and engineering take-off; organization of assets into lists or groups; reconciliation of total allocated costs to total actual costs; an explanation of the treatment of indirect costs; identification and listing of §1245 property; and consideration of related aspects such as §263A, a change in accounting method and sampling.
Does the IRS require an engineering-based study or a site visit?
The guide says the IRS has not established any requirements or standards for preparing studies, and it describes six approaches without mandating one. It does list a site visit among the documentation of a quality study. Every study is priced as a remote study, built from public property records, reliable secondary data, and the documents and photos you supply. When a walkthrough would improve the study, we do it with you on a video call at no charge. An in-person site visit is available as an add-on, when you want one or we recommend one, throughout the contiguous United States and Washington, DC; it covers the field visit and travel. Whether we recommend one depends on the property: its type, complexity, available documentation, and engagement scope. The IRS has set no required standard for cost segregation studies and does not mandate an on-site inspection; its Audit Techniques Guide (IRS Publication 5653) recommends one for quality studies, which is why a visit is offered as an option.
Does the guide cover residential rental property?
Yes. Chapter 7 includes a residential rental property matrix (Exhibit A) that recommends the classification and recovery period for assets commonly found in rentals, such as appliances, carpeting, fencing and parking areas. The guide tells examiners that when a taxpayer's return position is consistent with the matrix, they should not adjust the classification or recovery period.
Where do I get the official guide?
Download Publication 5653 directly from the IRS at irs.gov/pub/irs-pdf/p5653.pdf. This page is a companion to it, not a replacement: when you need the exact wording, rely on the IRS document.

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