Ezel / IRS Rulings / 200141008

CCA 200141008: Railroad employer status transfers between two businesses

Number
200141008
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
April 17, 2001
Publicly released
October 12, 2001
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2001, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2001
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The Railroad Retirement Board told the IRS that one redacted business became a rail carrier employer on September 30, 1999, while another ceased to be a covered employer on September 29, 1999. IRS counsel reviewed the Board's opinion and reached the same conclusions under the Railroad Retirement Tax Act. The memorandum directs the recipient to take appropriate action but does not disclose the businesses' identities or the underlying facts.

Ruling snapshot

  • Question: When did the two businesses gain or lose covered railroad employer status?
  • Outcome: Advice given: one became covered September 30, 1999; the other ceased September 29, 1999.
  • Key authorities: IRC § 3231.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224

APR 17 2001

Number: 200141008
Release Date: 10/12/2001
CC:TEGE:EOEG:ET1 - COR-103634-01
UILC: 3231.01-00

MEMORANDUM FOR

FROM: Office of Division Counsel/Associate Chief Counsel
(Tax Exempt and Government Entities)

SUBJECT: CC:TEGE:EOEG:ET1 - COR-103634-01
Railroad Retirement Act Tax Status

In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective September 30, 1999. The RRB also held that ceased being a covered employer under the Acts effective September 29, 1999. Both businesses have the following address:

We have reviewed the opinion of the RRB and, based upon the information submitted to the RRB, we also conclude that became a rail carrier employer under the Railroad Retirement Tax Act effective September 30, 1999. We also conclude that ceased being a covered employer under the Act effective September 29, 1999. Please take the appropriate action regarding these businesses.

Will E. McLeod cc:

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