Nevada Guardianship of the Estate: Accountings, Court Oversight and Fees

Part of my Nevada Guardianship of the Estate Guide.

By Ronald W. Brilliant, Attorney at Law · Licensed in Idaho, Nevada & California · Last reviewed: September 2026 against Nevada Revised Statutes chapters 159, 159A, 160, 161, 162 and 167 (current through the 2025 legislative session)

In This GuideNevada Guardianship of the EstateTopic 4 of 6: Accountings and Oversight

A Nevada guardian of the estate manages money and property for a protected person, meaning a person other than a minor for whom a guardian has been appointed (NRS 159.0253). Every guardianship must be reviewed by the court once a year (NRS 159.176), and a guardian who manages property must file regular written accounts showing what came in, what went out and what is left (NRS 159.177, 159.179).

This page covers when accounts are due, what they must contain, how the court reviews them, how guardians and attorneys are paid, and what happens when a guardian does not follow the rules. For a minor’s estate, see Managing a Minor’s Property.

When a Guardian Must File an Account

A guardian of the estate, or a special guardian who is authorized to manage the protected person’s property, must make and file a verified account (a sworn financial report) in the guardianship case at the times listed below (NRS 159.177(1)).

Event	When the account is due	NRS
Every year	No later than 60 days after the anniversary date of the guardian’s appointment, unless the court orders a different interval for good cause and with appropriate protection of the protected person’s interests	159.177(1)(a)
Guardian asks to resign	Upon filing the petition to resign and before the court accepts the resignation	159.177(1)(b)
Guardian is removed	Within 30 days after removal, unless the court allows longer	159.177(1)(c)
Guardianship ends or the protected person dies	Within 90 days after termination or death, unless the court allows longer	159.177(1)(d)
Other times	Whenever the law requires or the court orders	159.177(1)(e)

Each account must be served on the protected person’s attorney and, if the protected person is living, on the protected person (NRS 159.177(2)).

If, after all claims and expenses are paid, the protected person’s property is worth no more than $10,000, the court may grant a summary administration and may excuse annual accountings (NRS 159.076(1)-(2)). If the net value of the estate at any time exceeds $10,000, the guardian must file an amended inventory and accounting and must file annual accountings (NRS 159.076(4)). See Appointment and Bond.

What the Account Must Show

An account filed by a guardian of the estate, or by a special guardian authorized to manage property, must include at least the following (NRS 159.179(1)):

The period the account covers.
The protected person’s assets at the beginning and end of the period, including beginning and ending balances of any accounts.
All cash receipts and disbursements during the period, including payments for the protected person’s support and other estate expenses.
All claims filed and the action taken on them.
Any changes in the property from sales, exchanges, investments, acquisitions, gifts, mortgages or other transactions since the original inventory or the last account, including income received.
Any other information the guardian considers necessary to show the condition of the protected person’s affairs.
Any other information the court requires.

All expenditures must be itemized (NRS 159.179(2)). If one account covers the estates of two or more protected persons, it must show each person’s interest in the receipts, disbursements and property (NRS 159.179(3)). For how the inventory and day-to-day management work, see Managing the Estate.

Receipts and Vouchers

The guardian must keep receipts or vouchers for all expenditures and produce them when asked by the court, the protected person they relate to, that person’s attorney or any interested person. The guardian files them with the court only if the court orders it (NRS 159.179(4)).

On its own motion, or on an ex parte application by an interested person that shows good cause, the court may order the receipts or vouchers produced and may examine or audit them (NRS 159.179(5)). If a receipt is lost or for good reason cannot be produced, payment may be proved by the oath of at least one competent witness, subject to the conditions in NRS 159.179(6).

A guardian must keep all records and documents for each protected person for at least 7 years after the court ends the guardianship, and all financial records for at least 7 years after the last financial transaction (NRS 159.19905).

Court Review and Objections

Any interested person, meaning a person entitled to notice of the guardianship proceeding under NRS 159.034 (NRS 159.0195), may appear at the hearing on an account and object, or may file written objections before the hearing (NRS 159.181(1)). If there are no objections, or the court overrules them, the court may enter an order allowing and confirming the account (NRS 159.181(2)).

An order settling and allowing an account is generally a final order that binds everyone interested in the guardianship, including heirs and assigns (NRS 159.181(3)). It is not final against a protected person who asks to examine an account after his or her legal disability is removed (NRS 159.181(3)). An appeal may be taken from an order settling an account within 30 days after notice of its entry (NRS 159.375(3)).

If the court finds that a person did not object in good faith or in furtherance of the protected person’s best interests, the court may order that person to pay the estate all or part of the expenses caused by the objection (NRS 159.181(4)).

The Protected Person’s Rights

Nevada’s Protected Persons’ Bill of Rights says a protected person has the right to prudent financial management of his or her property and to regular detailed reports of financial accounting, including reports on investments, trusts held for his or her benefit, and expenditures or fees charged to the estate (NRS 159.328(1)(q)). The protected person also has the right to have a guardian’s services provided at a reasonable rate and to have a court review payment requests to avoid excessive or unnecessary fees or duplicative billing (NRS 159.328(1)(p)). More about these rights is on the Protected Persons’ Rights page.

A protected person or his or her attorney is entitled to receive copies of any accountings for trusts created by or for the benefit of the protected person (NRS 159.3395). The guardian or the protected person’s attorney may demand a copy of a trust and an accounting of its assets from the trustee, and may ask the court to assume jurisdiction of the trust if the trustee does not comply within 30 days after being served with the demand (NRS 159.339(2)-(3)).

How Guardians Are Paid

Subject to the court’s discretion and approval, a guardian must be allowed reasonable compensation for services, necessary and reasonable expenses of serving as guardian, and reasonable expenses of hiring accountants, attorneys, appraisers or other professionals (NRS 159.183(1)). Reasonable compensation must be based on similar services performed for persons who are not under a legal disability (NRS 159.183(2)). In deciding what is reasonable, the court may consider the nature of the guardianship, the type, duration and complexity of the services, and any other relevant factors (NRS 159.183(2)).

Unless the court has ordered someone else to pay, compensation and expenses must be paid from the protected person’s estate (NRS 159.183(3)).

Court approval first. No compensation or expenses, including attorney’s fees, may be paid from the estate unless and until the court approves the payment under NRS 159.183 or NRS 159.344, as applicable (NRS 159.183(4)).
No pay for losing a removal fight. If the court removes a guardian, the guardian is not allowed compensation or expenses, including attorney’s fees, for services resulting from the petition to remove him or her (NRS 159.183(5)).

Paying Attorney’s Fees From the Estate

Anyone who hires an attorney to represent a party in a guardianship case, including a guardian or proposed guardian, is personally liable for those attorney’s fees and costs (NRS 159.344(1)). Except as NRS 159.183(5) provides, that person may petition the court to have the fees and costs paid from the protected person’s estate, but they may not be paid from the estate unless and until the court authorizes it (NRS 159.344(2)).

Written notice at first appearance. When the person first appears in the case, he or she must file a written notice of intent to seek fees from the estate. The notice must explain the fee arrangement, list the hourly rates of all timekeepers, explain why the attorney’s services are necessary to further the protected person’s best interests, and be served on everyone entitled to notice. It is subject to court approval after a hearing (NRS 159.344(3)).
Petition for payment. If the notice was filed and approved, the person may petition for payment. The petition must describe the services in detail and itemize each task, with time recorded to the nearest one-tenth of an hour (NRS 159.344(4)).
Court review. The court may consider many factors, including whether the services actually benefited the protected person, the results of the work, customary fees, efficiency, the estate’s ability to pay, and whether the person or attorney unnecessarily expanded issues or delayed the case (NRS 159.344(5)).

The court may award only an attorney rate for work that requires an attorney, a paralegal rate for paralegal work, a fiduciary rate for fiduciary work, and nothing for secretarial or clerical work (NRS 159.344(5)(g)). The court may not approve compensation for an attorney’s internal business activities, or for time reported as a lump total for several tasks instead of itemized by task (NRS 159.344(6)).

When two or more parties litigate a contested issue, such as competing petitions to be appointed guardian, only the prevailing party may petition for fees from the estate (NRS 159.344(9)). If there is no prevailing party, the court may allow a portion of each party’s fees and costs to be paid from the estate if it finds them just, reasonable and necessary (NRS 159.344(9)).

Consequences for Misconduct

The court may impose a penalty of up to $5,000 and order restitution of misappropriated money if a guardian does any of the following (NRS 159.345):

Is guilty of gross impropriety in handling the protected person’s property.
Makes a substantial misstatement in a report under NRS 159.081 or an account under NRS 159.177.
Willfully fails to file a required report or account after receiving written notice from the court of the failure and a 2-month grace period has passed.

The penalty and restitution must be paid by the guardian, not by the protected person’s estate (NRS 159.345).

If a guardian violates a right of the protected person set forth in chapter 159, the court may take any appropriate action. Options include disallowing fees payable to the guardian, ordering compensation for losses after notice and a hearing, and removing the guardian (NRS 159.346(1)). If the guardian’s action is deemed deliberately harmful, fraudulent or malicious, the court may also impose twice the actual damages plus attorney’s fees and costs (NRS 159.346(2)).

Among other grounds, the court may remove a guardian of the estate who has mismanaged the estate, or a guardian who has intentionally failed to perform any duty required by law or a lawful court order, regardless of injury (NRS 159.185(1)(d), (f)). Removal and resignation are covered on the Changing or Ending a Guardianship page.

Final Accounting and Discharge

Before the court approves the resignation of a guardian of the estate, the court must require the guardian to submit, on the hearing date, an accounting of the estate through the end of the term (NRS 159.1877(1)). If the guardian fails to file it, the court may impose sanctions (NRS 159.1877(2)). If the estate has more than one guardian, the court may waive this accounting when the remaining guardian or guardians must file the annual accounting, if applicable, and are responsible for any discrepancies (NRS 159.1877(3)).

When a guardianship ends, the guardian of the estate winds up its affairs, including paying the expenses of administration (NRS 159.193). After winding up, the guardian must deliver the property to the protected person, the personal representative or the successor guardian, as the case may be, and obtain a receipt (NRS 159.197(1)). Once receipts and vouchers showing compliance with the court’s winding-up orders are filed, the court must discharge the guardian and exonerate the bond (NRS 159.199(1)). A guardian is not relieved of liability for his or her term until the discharge order is entered and filed (NRS 159.199(2)).

How I Can Help

I help Nevada guardians prepare and file accountings, respond to objections, and request court approval of guardian and attorney compensation. I also help family members and protected persons review accounts and raise concerns with the court when something does not look right. Request a consultation to discuss your situation.

This page provides general information about Nevada guardianship of the estate, based on the Nevada Revised Statutes as of the 2025 legislative session, and is not legal advice. Other Nevada laws, court rules, and case law also affect these matters. Every situation is different; consult an attorney about yours. Reading this page does not create an attorney-client relationship.