The usefulness of item response theory (IRT) models depends, in large part, on the accuracy of item and person parameter estimates. For the standard 3 parameter logistic model, for example, these parameters include the item parameters of difficulty, discrimination, and pseudo-chance, as well as the person ability parameter. Several factors impact traditional marginal maximum likelihood (ML) estimation of IRT model parameters, including sample size, with smaller samples generally being associated with lower parameter estimation accuracy, and inflated standard errors for the estimates. Given this deleterious impact of small samples on IRT model performance, use of these techniques with low-incidence populations, where it might prove to be particularly useful, estimation becomes difficult, especially with more complex models. Recently, a Pairwise estimation method for Rasch model parameters has been suggested for use with missing data, and may also hold promise for parameter estimation with small samples. This simulation study compared item difficulty parameter estimation accuracy of ML with the Pairwise approach to ascertain the benefits of this latter method. The results support the use of the Pairwise method with small samples, particularly for obtaining item location estimates.