...........Bottom line is there is nothing in USPAP preventing an appraiser from providing this type of service.......
The question is what type of service can you provide....and what do you sell to the public as your credentials to do so?
If Joe Schmo says he can help you save taxes the public wants credence and reputation. The credence and reputation is that you are a property value expert in your market because you are an appraiser. But how do you communicate to the public that you can be their advocate without telling the public you are a valuation expert (appraiser)?
In order to get the clients you need to tell the public you are an expert, aka, appraiser. So , now there is a fine line you have to walk because in order to get the business you are telling the public you are an appraiser; appraisers must follow USPAP.
What do you do at the initial consultation? Do you point out assessor errors? The profit margin in that is limited. Do you point out possible valuation errors? That is getting towards valuation services, which is appraisal practice.
The only way I know to provide tax appeal (assessed value) services is to tell the property owner that you will provide a service for them, but you cannot guarantee anything.
The general public is looking for guarantees for the most part, they want to know the $400-$4,000 they are spending will guarantee a decreased tax burden.
... anyone know the process of how the "valuation service" tax advocates operate?......
Many of them make the consumer believe that they will get lower taxes, inferred or implied. They have to make people believe that they will benefit, otherwise the market is limited. The general public does not want to "take a chance" that they will or will not save money.
.........If you haven't done an appraisal, how do you know whether to tell the client to proceed or not?...........
Therein lies the conundrum. You really can't tell someone to proceed if you do not form an opinion of value, high or low. That is acting as an appraiser.
It is my opinion that if you are going to provide any opinion value you have to have a strong engagement letter stating that the client may or may not have a case, and that if they do have a case there is no guarantee that the client will "win" in their efforts.
Tax work can be lucrative, but the rules must be followed, and USPAP is one of those rules. Be an advocate for your appraisal report, not the client; that is USPAP 101.