Office of Chief Counsel Internal Revenue Service Memorandum

BVLaw
Full Text of Court Cases
September 27, 2019
estate and gift taxation
fair market value (FMV), federal taxation, gift tax, merger, subsequent events, hypothetical buyer, valuation date

Office of Chief Counsel Internal Revenue Service Memorandum
POSTF-111979-17, Number 201939002
US
Federal Court
Federal
Office of Chief Counsel, Internal Revenue Service

Summary

IRS private letter ruling says that, under facts, gift tax valuation must consider merger that was being negotiated at the time the donor transferred company stock into a trust where the merger was only announced after the stock transfer and the announcement prompted an increase in stock value.
Private Letter Ruling Subsequent Events
PDF, Size: 72 KB

See Also

IRS Private Letter Ruling on Whether to Consider Pending Merger in Gift Tax Valuation

IRS private letter ruling says that, under facts, gift tax valuation must consider merger that was being negotiated at the time the donor transferred company stock into a trust where the merger was only announced after the stock transfer and the announcement prompted an increase in stock value.