In a private letter ruling, the IRS says that a pending merger is to be considered in valuing a company’s stock for gift tax purposes. In this case, a hypothetical purchaser could have reasonably foreseen the merger, so “to ignore the facts and circumstances of the pending merger would undermine the basic tenets of fair market value and yield a baseless valuation,” the IRS says in the ruling. For a copy of the ruling (201939002), click here. Note: The IRS issues a private letter ruling at the request of a taxpayer for the purpose of getting the agency’s opinion on a specific transaction or issue facing the taxpayer. Although anyone else can’t use it as precedent, it is useful in that it usually reflects the attitude of the IRS toward a particular tax matter.