"For the Johnson Controls/Tyco merger, do you have to
pay capital gains taxes on the fair market value of the shares before
the merger, or just on the cash received?
"
Really, the answer is "none of the above." You proceeds from the sale is the fair market value of the 231.4889 shares you received (277 x 0.8357) plus the cash received. From that you subtract the basis of your 277 shares.
I'm certain that the 1099-B is not listing as "proceeds" your original number of shares. Your original shares and all the shares acquired after that - dividend reinvestments? - constitute the basis of what you sold.
Tom Young