Quick answer: if the will directs or authorizes the sale, N.C.G.S. § 28A-17-8 lets the executor sell without going back to court. If it doesn't, and the sale is to pay debts, a special proceeding before the Clerk of Superior Court under Article 17 is the usual route. Run your own numbers in the North Carolina probate real estate sale calculator.
Why real property is treated differently to begin with
Path one: the will grants a power of sale
Under N.C.G.S. § 28A-17-8, when a will confers a power to sell, or directs that the property be sold, the personal representative may sell it without a special proceeding — while still following the will's own terms, executing and recording the deed, and honoring ordinary fiduciary duties to heirs and creditors.
Path two: the Article 17 petition, tied to paying debts
Where the will is silent, North Carolina's judicial route is narrower than in many other states: under Article 17 (§ 28A-17-1 through § 28A-17-7), the personal representative petitions the Clerk of Superior Court in the county where the property sits specifically to sell real property for the payment of debts and other claims against the estate. Heirs and devisees receive notice and can contest the petition; if the allegations aren't controverted, the clerk can summarily order the sale.
The two-year backstop
If neither a power of sale in the will nor a sale petition has been used within two years of the decedent's death, the heirs or devisees themselves may sell, lease, or mortgage the property directly — and once they do, that transaction becomes valid as to the estate's creditors and personal representative, effectively closing the window for the estate to unwind it.
Special proceedings to sell real estate are filed with the Clerk of Superior Court in the county where the property sits — Mecklenburg, Wake, and Guilford among the busiest — under the same statewide statute.
A local probate attorney can review your estate — many offer a free consultation.