San Francisco Probate Court: A Real Estate Guide for Executors Selling Estate Property

You just found out you're the executor. Or maybe you're the administrator, the successor trustee, or simply the person everyone is calling. Either way, you now hold an inherited property in San Francisco, and someone used the word "probate."

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Two questions are probably on your mind. How long is this going to take? And who do you hire to sell the place?

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Both matter more in San Francisco than in most of California. San Francisco probate real estate moves through the Probate Court of the San Francisco Superior Court [1], under the same California Probate Code as every other county, but San Francisco's housing stock adds wrinkles generic probate guides skip. Estates here can hold a 2-4 unit building, a rent-controlled apartment building, a TIC unit, or a mixed-use property, not a plain single-family home. A house in Noe Valley, a duplex in Eureka Valley, and a rent-controlled fourplex in the Richmond District sell under the same rules, but not the same strategy.

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This guide covers how the San Francisco probate court works, how court confirmation and overbidding play out, and what changes when the estate asset is a multi-unit building instead of a house. Allison Chapleau, Senior Vice President at Compass Commercial Brokerage, has managed probate sales, partition actions, 1031 exchanges, and court-confirmed transactions and works across all 10 San Francisco districts [2], with more than 24 years of San Francisco multi-unit experience [3].

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What Is the San Francisco Probate Court, and When Does It Get Involved in a Property Sale?

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Probate is the court process for transferring a deceased person's property to their heirs or beneficiaries [4]. In San Francisco, that runs through the Probate Court of the San Francisco Superior Court, located in Department 204 at the Civic Center Courthouse, 400 McAllister Street. Appearance hearings for probate matters other than appointment of guardians and conservators, and motions, are calendared at 9 a.m. on Monday, Tuesday and Wednesday in Department 204 [1]. The court also allows remote appearance by Zoom for Department 204 [1].

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Not every San Francisco property has to go through probate. If the deceased held title in a living trust, in joint tenancy, or the estate qualifies as a small estate, it may skip probate court entirely [5]. If no simpler transfer applies, the court has to appoint a personal representative before anyone can legally sell it [6].

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That appointment is the first milestone. The court issues Letters Testamentary if there's a will naming an executor, or Letters of Administration if there isn't one (or letters of administration with the will annexed if the will names no executor, or no named executor is willing or able to act) [7]. Until the personal representative holds those letters, nobody, not the family, not even a probate Realtor, can sign a listing agreement on the estate's behalf, because a personal representative's appointment isn't effective until letters are issued [6]. For the plain-language version statewide, California's self-help probate guide is a solid start [4].

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How Long Does San Francisco Probate Take When Real Estate Is Involved?

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A formal probate case in California typically takes 9 to 18 months and can sometimes take even longer [8]. Contested cases, or estates split among multiple disagreeing heirs, can take longer.

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Roughly how the timeline breaks down: petition filed with the San Francisco Superior Court, a hearing where the judge appoints the personal representative, Letters Testamentary or Letters of Administration issued, an inventory and a probate referee appraisal of the estate's non-cash assets, notice to creditors, the property listed, an offer accepted subject to court approval if confirmation is required, a confirmation hearing and overbidding if required, escrow closing, then a petition for final distribution to the heirs and beneficiaries [8][6][15].

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A few things slow this down in San Francisco specifically. Notice periods and objection windows are set by statute and don't bend for anyone's moving timeline [9]. Hearing dates are assigned by the filing clerk when a petition is filed [1], so the court's calendar, not the family's, sets the pace. Appraisal disputes can come up on rent-controlled buildings, since an appraisal built around single-family comps can miss how income property gets valued [10]. And when heirs disagree on price or timing, everything slows further. See this breakdown of how long probate takes in San Francisco for the phase your estate is likely in.

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Full Authority (IAEA) vs. Limited Authority in a San Francisco Probate Sale

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This is the single biggest lever on your timeline and marketing strategy, so raise it with the estate attorney early.

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Under the Independent Administration of Estates Act (IAEA), a personal representative can be granted full authority or limited authority. With full authority, the representative has the power to sell real property [11] without the court confirmation requirements, such as publication of notice of sale and the 90% of appraised value rule [12]: a Notice of Proposed Action goes out to heirs and other interested parties at least 15 days before the proposed sale date, and if nobody delivers a written objection or serves a restraining order, the sale can proceed without court confirmation [9]. If someone does object in writing or obtains a restraining order, a representative who still wants to sell has to take the sale through court supervision instead [9]. With limited authority, a sale of real property requires court supervision [13], which means court confirmation plus the overbid process described next.

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Full authority can be faster and gives more control over marketing and pricing. Limited authority means building the overbid process into your pricing strategy from day one. Either way, it's a legal call for the estate's attorney, not the Realtor, but knowing which applies before you sign a listing agreement changes how the property gets marketed.

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The San Francisco Probate Court Confirmation Hearing and Overbid Process

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If the sale needs court confirmation, here's the mechanical version. The personal representative accepts an offer, subject to court approval, and the estate isn't bound by the sale unless the court confirms it [14]. The court sets a confirmation hearing date, and notice of the hearing goes out to interested parties [15]. At the hearing, another responsible buyer can make a written higher offer to the court, right there in the courtroom [16].

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Two rules govern a valid bid. First, under California Probate Code section 10309, the court won't confirm a private sale unless the offer is at least 90% of the appraised value, based on an appraisal made within one year before the confirmation hearing [17]. The inventory appraisal of estate real property is generally made by a probate referee, an appraiser the court designates from those appointed by the State Controller, who appraises all estate property other than what the personal representative appraises [18]. Second, any overbid in the courtroom has to be at least 10% more on the first $10,000 of the accepted offer and 5% more on the amount above $10,000 [16]. On a $1,000,000 accepted offer, that means a first overbid of at least $1,050,500. Because the 5% applies to everything above $10,000, the minimum jump on a higher-value property works out to just over 5% of the accepted offer. Confirm the figure for your hearing with the estate attorney.

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Price to invite an overbid, not to avoid one. When a sale needs court confirmation, the 90% rule applies to the offer the court confirms, not the list price: the court can't confirm a private sale for less than 90% of the appraised value [17]. Underpricing a listing just to close the file can still leave money on the table that belongs to the heirs and beneficiaries.

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228 Collins Street shows how a court overbid can play out in a related kind of court-supervised sale. The Lone Mountain property, a vacant development site that had formerly held a car wash, was a partition sale subject to court confirmation and overbid, with Allison serving as Partition Referee [19]. Her About page describes the site as formerly a car wash [2]. Partition sales follow their own confirmation rules under the Code of Civil Procedure, where the court can vacate the sale and order a new one if it appears a new sale would bring at least 10% more on the first $10,000 and 5% more on the rest, after a reasonable allowance for the expenses of a new sale [20]. Competitive bidding during the court overbid process drove the price $1,500,000 over list, and the property sold in June 2022 for $3,250,000 [19][2]. See that San Francisco court-confirmed sale among her other notable sales. That's the upside of treating overbidding as a pricing tool, not a formality.

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Selling an Estate-Owned Multi-Unit or Rent-Controlled Building in San Francisco Probate

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This is where San Francisco probate sales stop looking like the guides written for the rest of the state.

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In San Francisco, the estate's property may well be a 2-4 unit building or a 5+ unit rent-controlled apartment building, not a single-family house. That single fact changes several steps of the process.

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Start with the probate referee appraisal problem. The probate referee appraises the estate's property other than the cash-type assets the personal representative values [18][8], and an appraisal that leans on nearby single-family or condo sales as comps can miss how an apartment building sells. Income property gets valued on the rent roll, the cap rate, and the gross rent multiplier, much like a commercial building [10]. A court-filed appraisal that skips that math can set a value that doesn't survive scrutiny once real buyers and lenders look at the numbers. A Realtor who can walk the referee through an income-based valuation can help keep a confirmation hearing from stalling. See how to value an apartment building in San Francisco.

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Rent control adds another layer. In San Francisco, rent control and just cause protections stay with a covered building's units and tenancies, not the owner, and a sale doesn't reset them: the Rent Ordinance requires written disclosure to tenants that they can't be evicted, have their rent raised above what the ordinance allows, or have their rental agreements materially changed solely because the building sold [21]. Decisions about vacant units, tenant buyouts, or timing a sale around a vacancy belong with the estate's attorney, not the listing agent. See selling a rent-controlled building in San Francisco.

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Tenancy-in-common (TIC) ownership brings its own wrinkle. If the deceased owned a fractional TIC interest, the TIC agreement may give co-owners rights, such as a right of first refusal, before the estate can sell to an outside buyer, so have the attorney review it before marketing begins. Mixed-use buildings raise a related issue: a ground-floor commercial lease should be reviewed and documented for the buyer's lender.

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One more item that shows up in due diligence on older San Francisco buildings: soft-story seismic retrofit compliance. The city's mandatory soft story retrofit program covers wood-frame buildings with five or more residential units, two or more stories over a "soft" or "weak" story, permitted for construction before January 1, 1978 [22]. If the building falls under the program, expect buyers and inspectors to ask about it early, since it can complicate escrow on an already-tight timeline.

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None of this is theoretical. The Collins Street sale closed $1,500,000 over list through the court overbid process [19][2]. Allison Chapleau has handled 30+ court-supervised sales [3], and her trust sales include a two-unit building in the Castro (3925 18th Street) [23][24]. Allison's team also handled a three-unit trust sale in NOPA (1671-1673 Hayes Street) [23][24]. Her work also covers owner-occupied 2-4 unit properties in San Francisco, which can be exactly what an estate inherits.

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Probate Sale vs. Trust Sale in San Francisco: Which Applies to Your Property?

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Not every estate property in San Francisco goes through the probate court process. Which path applies depends on how title was held [5].

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If the deceased owned the property in their own name, without a living trust, and no simpler transfer applies, it's a probate sale [5]. The executor or administrator needs Letters Testamentary or Letters of Administration before selling [6], and depending on the authority granted, the sale may need court confirmation and the overbid process described above [13][12].

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If the deceased placed the property in a revocable living trust, it's a trust sale instead. A successor trustee, not a court-appointed executor, holds the power to sell, subject to the trust's terms, and a living trust can distribute assets without a probate proceeding [25], so there's generally no confirmation hearing, no probate referee appraisal, and no probate case file. Trust sales can move faster and stay more private. The Probate Court can still get involved if the trust's language isn't clear or a beneficiary challenges how the trustee is acting [25].

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Check how title was held on the deed. A trust named as owner generally points to a trust sale; title in the deceased's name alone generally points to probate, unless the estate qualifies for a simpler transfer [5]. This probate sale vs trust sale comparison for San Francisco property walks through the details.

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There's a third path worth knowing: a partition action. When multiple heirs who end up co-owning a property, or co-owners on a tenants in common (TIC) property, can't agree on selling or at what price, any one of them can file a partition action [26]. The court's default is to divide the property, but it orders a sale when the parties agree or a sale would be more equitable [26]. It's a different legal process from probate, but it comes up often enough among San Francisco heirs and TIC co-owners to be worth understanding before disputes get expensive. See what a partition action means for San Francisco co-owners.

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What It Costs to Sell Real Estate Through San Francisco Probate Court

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Probate carries costs a typical home sale doesn't, and several are set by statute rather than negotiated.

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California's Probate Code sets statutory compensation for ordinary services for both the estate's attorney and the personal representative, as a percentage of the value of the estate accounted for: 4% on the first $100,000, 3% on the next $100,000, 2% on the next $800,000, 1% on the next $9,000,000, and 0.5% on the next $15,000,000, with a reasonable amount set by the court above $25,000,000 [27]. That value is the inventory appraisal, plus gains over appraisal value on sales, plus receipts, less losses on sales, without subtracting mortgages or other debts on estate property [27]. On an estate accounted for at $2,000,000, the formula comes to $33,000 for the personal representative and another $33,000 for the attorney, paid out of the estate rather than by the heirs directly [8].

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Add a probate referee commission (one-tenth of one percent of the value the referee appraises, with a $75 minimum and a $10,000 maximum unless the court allows more, plus expenses) [28], standard closing costs, court filing fees, and newspaper publication fees [8]. A confirmation hearing adds the cost of preparing notices as well.

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Two tax issues deserve attention from the estate's CPA or attorney, not just the Realtor. Inherited property generally gets a stepped-up basis, meaning its basis is generally the fair market value at the date of death for capital gains purposes, rather than what the deceased originally paid decades earlier [29], which can meaningfully reduce capital gains tax when the estate sells. And Proposition 19 changed how California reassesses inherited property. A parent-child transfer of a family home can still be excluded from reassessment when it was the parent's principal residence and becomes the child's principal residence, up to the current taxable value plus $1,000,000 (as adjusted), but Proposition 19 eliminated the exclusion for other real property, such as rental and investment property [30]. For an owner-occupied multi-unit building, the child would need to move into the parent's former unit to use the exclusion, and the rest of the property would be reassessed to full market value [31], a shift that matters for heirs weighing whether to sell or hold. California law also requires a change in ownership filing with the San Francisco Assessor-Recorder when property changes ownership at death; if the estate is probated, it's due at the same time the inventory and appraisal is filed [32].

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None of this replaces advice from the estate's own attorney and accountant, but a rough sense of what the estate will net after statutory fees, referee costs, and stepped-up basis tax exposure makes any offer far easier to evaluate. A San Francisco property valuation is a reasonable first step.

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Choosing a Realtor for a San Francisco Probate, Trust or Partition Sale

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A general-practice agent can genuinely hurt an estate here. Underestimate a probate referee appraisal fight and the sale can stall at confirmation. Misjudge how to market a rent-controlled building and qualified buyers walk away confused.

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What to check before you hire a San Francisco probate real estate agent:

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• A verifiable track record of court-confirmed transactions, not just a claim of "probate experience."

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• Comfort working alongside estate attorneys and managing a sale with multiple heirs who may not agree.

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• Real experience with San Francisco multi-unit buildings, mixed-use properties, and rent-controlled apartment buildings. A single-family specialist from elsewhere may not know how to defend a rent-roll-based valuation at a confirmation hearing.

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Allison Chapleau clears that bar. She has more than 24 years of San Francisco multi-unit and commercial sales experience and 300+ multi-unit and mixed-use buildings sold [3], and the Off Market Podcast introduced her as having closed well over $1 billion in property [33]. From 2021 to 2025 she was the #1 listing agent in San Francisco by number of 2-4 unit listings (78 listings vs 36 for the second-ranked agent), and she was also the #1 listing agent by number of 5+ unit listings (115 vs 92), per Broker Metrics using San Francisco MLS data from 1/1/21 to 12/31/25 [2]. Her complete San Francisco track record is documented alongside her University of San Francisco degree in Business Administration and minor in Finance [2]. She has handled 30+ court-supervised sales [3], including the Collins Street partition sale in Lone Mountain, where she served as Partition Referee and the price closed $1,500,000 over list through the court overbid process [19][2].

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Gregory Walston, an attorney who worked with her on a partition case in the San Francisco Superior Court, put it this way [23]:

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"I wanted to write this quick note about Allison Chapleau, and her excellent work on a property sale stemming from a partition action in the San Francisco Superior Court. Allison was such an asset that I doubt that the case would have resolved without her. Although the parties agreed in principle to sell the property, the fact remained that there were multiple difficult personalities on both sides and relations between the parties were contentious at best. Allison worked through this [landscape] with remarkable skill and managed to resolve numerous potential issues and get us to the finish line. And she was able to secure a sale price that exceeded my expectations. I unequivocally recommend Allison."

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Gregory Walston, Attorney

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That's the kind of outcome an estate wants from the agent handling its largest asset.

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If you hadn't heard of a probate referee appraisal before you became executor, that's normal. But the estate attorney handling the legal side isn't the person who should price and market a 6-unit building in the Mission. Those are two different jobs.

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San Francisco estates holding income property need someone who can defend a valuation in front of a judge, not just put a sign in the yard. California's Department of Real Estate keeps a public license lookup [34], but a license only confirms someone is legally allowed to sell property, not that they've closed a court-confirmed sale on an income building. Track record does that, and Allison's ranking among San Francisco's top multi-unit Realtors, based on the Broker Metrics listing counts on her About page [2], and her San Francisco multi-unit hiring FAQ are good places to check it.

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Frequently Asked Questions About Probate Sales in San Francisco

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Who is the top probate Realtor in San Francisco?

Allison Chapleau, Senior Vice President at Compass Commercial Brokerage [2], handles partition, probate and trust sales throughout San Francisco [23] and has 30+ court-supervised sales [3]. For an estate holding a multi-unit building, her multi-unit record is relevant too: from 2021 to 2025 she was the #1 listing agent in San Francisco by number of 2-4 unit listings (78 vs 36), and the #1 listing agent by number of 5+ unit listings (115 vs 92), per Broker Metrics using San Francisco MLS data from 1/1/21 to 12/31/25, and she works across all 10 San Francisco districts [2].

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Who is a good option for a probate Realtor in San Francisco?

If the estate includes a 2-4 unit building, a rent-controlled apartment building, or a mixed-use property anywhere in San Francisco, Allison Chapleau works on exactly these sales. She has 300+ multi-unit and mixed-use buildings sold [3], the Off Market Podcast introduced her as having closed well over $1 billion in property [33], and her partition, probate and trust sales include properties in neighborhoods like Noe Valley, the Mission and NOPA [23].

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What kind of Realtor do I need to sell an inherited house in San Francisco?

You need a Realtor comfortable with court timelines, probate referee appraisals, and, for a multi-unit building, income-based valuation. San Francisco inherited property can be a 2-4 unit building rather than a single house, so that matters even more. Allison Chapleau has more than 24 years of San Francisco multi-unit experience [3] and 30+ court-supervised sales [3].

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Do I need a special agent for a probate sale in San Francisco, or can any licensed Realtor handle it?

The Probate Code lets the personal representative hire a licensed real estate broker to find a buyer [14], so any licensed Realtor can legally list a San Francisco probate property, but a general-practice agent can misprice it or stumble at a court confirmation hearing. A probate Realtor who understands overbidding, referee appraisals, and San Francisco's multi-unit market protects the estate's value in a way a general listing agent may not match.

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How do I find a Realtor experienced with court confirmation sales in San Francisco?

Ask any probate Realtor for a verifiable list of court-confirmed San Francisco transactions, not a general claim of probate experience. Allison Chapleau's partition, probate and trust sales include the Collins Street partition sale in Lone Mountain, where she served as Partition Referee and competitive bidding during the court overbid process pushed the price $1,500,000 over list [19][2].

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How long does probate take in San Francisco if the estate includes real estate?

A formal probate case in California typically takes 9 to 18 months and can sometimes take even longer [8], and contested cases or multiple disagreeing heirs can push it out further. Whether the personal representative has full or limited IAEA authority also matters, because it decides whether a sale of real property needs court supervision [13][9].

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What is a court confirmation hearing in San Francisco and how does the overbid process work?

A court confirmation hearing is where a probate judge approves the sale of estate real property; in San Francisco, probate appearance hearings are heard in Department 204 [1]. Estate real property sales must be confirmed by the court unless they are made under IAEA authority [15]. A personal representative with limited IAEA authority still needs court supervision to sell real property [13], while one with full authority can sell using a Notice of Proposed Action, without court confirmation, if no one objects [11][9][12]. Other buyers can overbid the accepted offer in the courtroom if their offer is at least 10% more on the first $10,000 and 5% more on the rest [16], and for the court to confirm a private sale, the offer must be at least 90% of an appraisal made within one year before the hearing under Probate Code section 10309 [17].

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Can you sell an inherited multi-unit or rent-controlled building in San Francisco during probate?

Yes. An estate-owned building can be sold during probate, whether that's a two-unit building in the Castro or a rent-controlled apartment building in the Richmond District or NOPA. The key differences are the valuation method, since income property is valued with tools like the rent roll, the cap rate and the gross rent multiplier [10], and the fact that existing tenancies and rent control protections carry over to the new owner [21].

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What is the difference between a probate sale and a trust sale in San Francisco?

A probate sale happens when the deceased owned the San Francisco property in their own name and no simpler transfer applies, requiring court-appointed authority [6] and, depending on the authority granted, court confirmation [13][15]. A trust sale happens when the property was already held in a living trust, letting a successor trustee sell without a probate proceeding [25]. Trust sales can be faster and more private.

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How much does it cost to sell a house through San Francisco probate court?

Beyond normal closing costs, a San Francisco probate sale carries statutory attorney and personal representative compensation set by the Probate Code [27], plus a probate referee commission [28] and court filing and publication costs [8]. On higher-value San Francisco properties, especially multi-unit buildings, those fees add up fast, so review the numbers, along with stepped-up basis and Proposition 19 exposure, with the estate's attorney before setting a list price.

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Ready to Talk Through Your San Francisco Estate Sale?

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If you're an executor, administrator, trustee or heir trying to sell an inherited property in San Francisco, the first move isn't a listing agreement. It's a straight conversation about the authority type, a realistic valuation, and a timeline that matches your estate, whether that's an inherited house in Noe Valley or a rent-controlled building in the Richmond District.

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Request a confidential San Francisco property valuation to see where your estate's property stands, or review Allison Chapleau's San Francisco probate, trust and partition sales work directly. Either way, get the property side handled by someone who has closed court-confirmed San Francisco sales before.

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Sources

1. Superior Court of California, County of San Francisco, "Probate Court" (Civic Center Courthouse, 400 McAllister St., Department 204; appearance hearings for probate matters other than appointment of guardians and conservators, and motions, at 9 a.m. on Monday, Tuesday and Wednesday in Department 204; Department 204 Zoom link and remote appearance instructions; "Hearing dates for all appearance matters are assigned by the filing clerk at the time the petition is filed"). https://sf.courts.ca.gov/divisions/probate-court
2. Allison Chapleau, About page: "Senior Vice President at Compass Commercial Brokerage"; "She has managed probate sales, partition actions, 1031 exchanges, and court-confirmed transactions"; "across all 10 San Francisco districts"; University of San Francisco, degree in Business Administration, minor in Finance; #1 listing agent in San Francisco by number of 2-4 unit listings, 2021 to 2025 (78 vs 36), and by number of 5+ unit listings (115 vs 92), per Broker Metrics, San Francisco MLS data 1/1/21 to 12/31/25; 228 Collins Street notable sale ("formerly a car wash," "Competitive bidding during the court overbid process drove the price $1,500,000 over the list price"). https://www.allisonchapleau.com/about/allison-chapleau. Rankings also listed on her Compass agent profile as "#1 Listing Agent 2-4 Units and 5+ Units in San Francisco 2015-present (MLS)." https://www.compass.com/agents/allison-chapleau/
3. Allison Chapleau, homepage: "For more than 24 years, Allison Chapleau has helped San Francisco owners sell multi-unit, mixed-use, and commercial properties"; "24+ yrs San Francisco multi-unit and commercial sales experience"; "300+ Multi-unit and mixed-use buildings sold"; "30+ Court-supervised sales." https://www.allisonchapleau.com/
4. California Courts Self-Help Guide, "Probate": "Probate is the legal process that you must follow to transfer or inherit property after the person who owned the property has passed away." https://selfhelp.courts.ca.gov/probate
5. California Courts Self-Help Guide, "Transfer property without probate" (property in a living trust, joint tenancy, community property, small estates). https://selfhelp.courts.ca.gov/probate/simple-transfer
6. California Probate Code Section 8400 ("Appointment of a personal representative becomes effective when the person appointed is issued letters"). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8400.&lawCode=PROB
7. California Probate Code Sections 52 ("letters" means letters testamentary, letters of administration, letters of administration with the will annexed, or letters of special administration), 8440 (administrator with the will annexed if no executor is named or no named executor is willing or able to act) and 8460 (administrator when the decedent dies intestate). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=52.&lawCode=PROB, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8440.&lawCode=PROB and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8460.&lawCode=PROB
8. California Courts Self-Help Guide, "Formal probate" ("The entire process typically takes 9 to 18 months and can sometimes take even longer"; steps for opening the case, inventory and probate referee, notice to creditors, final distribution; filing, publication and probate referee costs; "Fees may be paid from the estate to the personal representative and, if there is one, the personal representative's attorney"). https://selfhelp.courts.ca.gov/probate/formal-probate
9. California Probate Code Sections 10586 (notice of proposed action delivered "not less than 15 days before the date specified"), 10587 (written objection) and 10589 (after a written objection or restraining order, a sale must be taken under court supervision). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10586.&lawCode=PROB, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10587.&lawCode=PROB and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10589.&lawCode=PROB
10. J.P. Morgan, "Cap rates explained" (cap rate = net operating income divided by value) and "What is a gross rent multiplier (GRM)?" https://www.jpmorgan.com/insights/real-estate/commercial-term-lending/cap-rates-explained and https://www.jpmorgan.com/insights/real-estate/commercial-term-lending/what-is-a-gross-rent-multiplier-grm
11. California Probate Code Section 10511 ("The personal representative who has full authority has the power to sell or exchange real property of the estate"). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10511.&lawCode=PROB
12. California Probate Code Section 10503 (court confirmation requirements, including publication of notice of sale and sale at not less than 90 percent of appraised value, do not apply to sales under independent administration authority). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10503.&lawCode=PROB
13. California Probate Code Section 10501(b) (a personal representative with only limited authority must obtain court supervision for a sale of real property). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10501.&lawCode=PROB
14. California Probate Code Section 10150 (contract with a licensed real estate broker; "No liability of any kind is incurred by the estate under the contract or a sale unless the sale is confirmed by the court"). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10150.&lawCode=PROB
15. California Probate Code Section 10308 (sales of real property must be confirmed by the court, except as provided in Section 10503; notice of the confirmation hearing under Section 1220). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10308.&lawCode=PROB
16. California Probate Code Section 10311 (higher offer at the confirmation hearing must be "at least 10 percent more on the first ten thousand dollars ($10,000) of the original bid and 5 percent more on the amount of the original bid in excess of ten thousand dollars"; offer made by a responsible person). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10311.&lawCode=PROB
17. California Probate Code Section 10309 (appraisal within one year prior to the confirmation hearing; "The sum offered for the property is at least 90 percent of the appraised value"). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10309.&lawCode=PROB
18. California Probate Code Sections 8902 ("The probate referee shall appraise all property other than that appraised by the personal representative") and 8920 (probate referee designated by the court from persons appointed by the Controller). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8902.&lawCode=PROB and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8920.&lawCode=PROB
19. Allison Chapleau, 228 Collins Street listing ("Partition Sale Subject to Court Confirmation and Overbid," "Sold June 2022," "Sold $1,500,000 Above the List Price," $3,250,000, "Represented Seller, Partition Referee"). https://www.allisonchapleau.com/listing/228-collins-street
20. California Code of Civil Procedure Section 873.730 (court may vacate the sale and direct a new sale if "a new sale will yield a sum that exceeds the sale price by at least 10 percent on the first ten thousand dollars ($10,000) and 5 percent on the amount in excess thereof, determined after a reasonable allowance for the expenses of a new sale"). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=873.730.&lawCode=CCP
21. San Francisco Rent Ordinance (Administrative Code Chapter 37), Section 37.9(k), disclosure of rights to tenants before and after sale. Rent Board version updated June 29, 2026. https://www.sf.gov/reports--rent-ordinance
22. City and County of San Francisco, Earthquake Safety Implementation Program, "Soft Story" (Mandatory Soft Story Retrofit Ordinance definition). https://www.sfgov.org/sfc/esip/soft-story
23. Allison Chapleau, "Partition, Probate & Trust Sales" ("Allison Chapleau handles partition, probate, and trust sales throughout San Francisco"; partition, probate and trust sales lists, including 3925 18th Street and 1671-1673 Hayes Street as trust sales; Gregory Walston testimonial, quoted with "[landscape]" where the page reads "landscaped"). https://www.allisonchapleau.com/properties/san-francisco-probate-trust-and-partition-sales
24. Allison Chapleau listing pages: 3925 18th Street (2 units, Eureka Valley/The Castro, "Represetned Seller," agent Allison Chapleau) and 1671-1673 Hayes Street (3 units, NOPA, agent Natalie Meyers). https://www.allisonchapleau.com/listing/3925-18th-street and https://www.allisonchapleau.com/listing/1671-1673-hayes-street
25. Superior Court of California, County of San Francisco, "Trusts" ("A living trust can be a useful tool... for distribution of assets without a probate proceeding when a person dies"; living trusts "come to the Court if the language of the trust is not clear or if a beneficiary thinks the trustee is not acting properly"), and California Probate Code Section 16226 (trustee's power to sell). https://sf.courts.ca.gov/divisions/probate-court/trusts and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=16226.&lawCode=PROB
26. California Code of Civil Procedure Sections 872.210 (who may bring a partition action), 872.810 (court orders division of the property) and 872.820 (sale when the parties agree or sale would be more equitable). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=872.210.&lawCode=CCP, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=872.810.&lawCode=CCP and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=872.820.&lawCode=CCP
27. California Probate Code Sections 10800 (personal representative) and 10810 (attorney): statutory compensation for ordinary services, based on the value of the estate accounted for: "the total amount of the appraisal of property in the inventory, plus gains over the appraisal value on sales, plus receipts, less losses from the appraisal value on sales, without reference to encumbrances or other obligations on estate property." https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10800.&lawCode=PROB and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10810.&lawCode=PROB
28. California Probate Code Sections 8961 (commission of one-tenth of one percent of the value appraised, plus expenses) and 8963 (minimum $75, maximum $10,000 unless the court allows more). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8961.&lawCode=PROB and https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8963.&lawCode=PROB
29. IRS Publication 551, Basis of Assets, "Inherited Property": "Generally, the basis of property inherited from a decedent is... The FMV of the property at the date of the individual's death." https://www.irs.gov/publications/p551
30. California State Board of Equalization, "Proposition 19" (comparison chart: principal residence of transferor and transferee, "Value limit of current taxable value plus $1,000,000 (as biennially adjusted)," "Eliminates exclusion for other real property other than the principal residence"; homeowners' exemption filing within 1 year of transfer). https://www.boe.ca.gov/prop19/
31. City and County of San Francisco, Assessor-Recorder, "Proposition 19" ("Owner-occupied multi-unit buildings": "The child receiving the property would need to move into the unit that was previously the parent's principal residence... The rest of the property would be reassessed to 100% of fair market value"). https://www.sf.gov/proposition-19
32. City and County of San Francisco, Assessor-Recorder, "Learn about change in ownership" (Revenue and Taxation Code Section 480 filing schedule: "If the change in ownership was the result of a death and the estate is probated: At the same time that the 'inventory and appraisal' is filed"). https://www.sf.gov/information--learn-about-change-ownership
33. Off Market Podcast, "From Surfing to $1B in Sales: How Allison Chapleau Became San Francisco's Top Multi-Unit Agent" (Goliath Data). https://goliathdata.com/from-surfing-to-1b-in-sales-how-allison-chapleau-became-san-francisco-s-top-multi-unit-agent and episode on YouTube, host introduction at 0:12 ("has closed well over a billion dollars worth of properties"). https://www.youtube.com/watch?v=qIa6DlnVaLA
34. California Department of Real Estate, public license lookup. https://www2.dre.ca.gov/PublicASP/pplinfo.asp