Probate sales with a court referee appraisal are required by the Probate Court to sell within no less than 90% of the value. Referee values are part of the I and A, “Inventory and Appraisal” completed by the referee. A referee is a court appraiser who establishes the values of estate property. These values are then made part of the document for the Probate Court called an “I and A.” The referee generally completes a drive-by exterior appraisal on vacant property. They are not always completely accurate.